Name(s) of Defendant(s)
                         Defendants
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Pursuant to Rule 34 of the [your state name] Rules of Civil  Procedure. Plaintiff/Defendant [your name] requests [a party] to produce at [your address]  copies of the documents set out below, pursuant to the following instructions and in accordance with the following definitions.

 1.    You are required to serve a written response to this Request within 30 days after service, except that if you are a defendant you are not required to serve a response until 45 days after service of the summons and complaint upon you.  Your response must state, with respect to each item or category, that you will produce the documents or tangible things requested and that inspection and copying, testing, or sampling will be permitted as requested unless you object to the Request, in which event the Request must be objected to and the reasons for the objection must be stated as set out in Instructions 5 & 6 below.  If objection is made to part of an item or category, the part objected to must be specified and the remainder of the Request granted.  The written response is due within 30 days after service of this Request.  It is important that your written response be served promptly so that any objection or claim of privilege may be resolved in advance of production.

2.    You are required to produce and permit inspection and copying of every requested document and the inspection and copying, testing, or sampling of each tangible thing that is in your possession, custody, or control or that is in the possession, custody, or control of your principals, agents, employees, attorneys, representatives, insurers, any persons or entities acting or purporting to act on your behalf, and any other persons or entities in active concert and participation with you, whether past or present and without regard to whether their relationship with you currently exists or has been terminated.

3.   You are required to produce pursuant to this Request every requested document and tangible thing currently known to you and every requested document and tangible thing that can be located or discovered by reasonably diligent efforts.

4.    You are required to produce pursuant to this Request the original of every requested document and tangible thing and any copies that have been altered in any way or that contain on their face additional markings, comments, or information. If the original of any document is not available, the most legible copy should be produced.

5.    You are required, if you object to the production, inspection, or copying of any requested document on the ground of privilege, work product, trade secret, or on any other grounds, to state for each such document: (i) its customary name or description and its identifying number, if any; (ii) the date of the document; (iii) the name and address of each person who prepared the document; (iv) the name and address of each person or entity who received the document or any copy thereof; (v) a summary of its substance; (vi) the name and address of each person or entity who has possession, custody, or control of the document or tangible thing or any copy thereof; and (vii) the precise nature of the objection made and a complete description of all facts, if any, upon which the objection is based.

6.    You are required, if you object to the production of any requested tangible thing or to any requested inspection, copying, testing, or sampling on the ground of privilege, work product, trade secret, or on any other ground, to state for each such tangible thing: (i) its customary name or description and its identifying number, if any; (ii) the date the tangible thing was made or produced and, if you did not make or produce the tangible thing, the date you acquired it; (iii) the name and address of each person or entity who made or produced the tangible thing; (iv) the name and address of each person or entity who has possession, custody, or control of the tangible thing or any copy thereof; (v) a description of the efforts taken by you to obtain the tangible thing; and (vi) the reasons, if any, given by the person or entity in possession, custody, or control of the tangible thing for not providing it to you.

7.    The documents to be produced pursuant to this Request  must be produced either as they are kept in the usual course of business or they must be organized and labelled to correspond with the categories in this Request.

8.    You are required, if you are unable to obtain any document required to be produced pursuant to this Request because the document is in the possession, custody, or control of any other person or entity, to state for each such document: (i) its customary name or description and its identifying number, if any; (ii) the date of the document; (iii) the name and address of each person who prepared the document; (iv) the name and address of each person or entity who has possession of the document or any copy thereof; (v) a summary of its substance; (vi) a description of the efforts taken by you to obtain the document; and (vii) the reasons, if any, given by the person or entity in possession, custody, or control of the document for not providing it to you.

9.    You are required, if you are unable to obtain any tangible thing requested to be produced pursuant to this Request because the tangible thing is in the possession, custody, or control of any other person or entity, to state for each such tangible thing: (i) its customary name or description and its identifying number, if any; (ii) the date the tangible thing was made or produced and, if you did not make or produce the tangible thing, the date you acquired it; (iii) the name and address of each person or entity who made or produced the tangible thing; (iv) the name and address of each person or entity who has possession, custody, or control of the tangible thing or any copy thereof; (v) a description of the efforts taken by you to obtain the tangible thing; and (vi) the reasons, if any, given by the person or entity in possession, custody, or control of the tangible thing for not providing it to you.

10.    All attachments to any requested documents that are stapled, paper clipped, or otherwise affixed to documents must be produced and must be attached to the document to which they relate.

11.    Unless otherwise specified this Request for production covers all of the documents and/or tangible things that were produced or in existence at any time during the period beginning 1980 to current date, e.g., the date your response to this request is served.

12.    YOU ARE REQUESTED PURSUANT TO RULE 26(e)(3) TO SUPPLEMENT SEASONABLY ALL OF YOUR RESPONSES TO THIS REQUEST TO INCLUDE INFORMATION, DOCUMENTS, AND TANGIBLE THINGS ACQUIRED AFTER SERVICE OF YOUR RESPONSE TO THIS REQUEST.

The term "document" is used in this Request in its broadest sense and means any record of information, of any kind or description, however made, produced, or reproduced, whether by hand or by any electronic, photographic, mechanical, or other process. Documents can take the form of any medium on which information can be stored including, without limitation, computer memory, film, paper, phonograph records, tape recordings, videotapes, and video disks.

The term "document" includes all drafts, all originals, and all non-identical copies, whether different from the original by reason of any notation made on such copies or otherwise.

The term "document" includes, without limitation, the following: accounts, advertising, affidavits, agreements, analyses, appointment books, appraisals, audiotapes, audio-videotapes, authorizations, bank statements, bills, blueprints, books, books of account, brochures, bulletins, calendars, catalogues, CDs, charts, checks, checkbooks, check stubs, circulars, communications, compilations, computer backup and/or storage accessories, computer disks, computer files, confirmations, contracts, correspondence, diaries, directives, drawings, drafts, DVDs, evaluations, files, filings with any governmental agency, film, forms, graphs, hospital records, inspection reports, instructions, insurance policies, interviews, invoices, journals, letters, logs, maintenance records, manuals, maps, medical records, memoranda, minutes, newspapers, notes, notebooks, notecharts, office reports, opinions or reports of consultants, orders, paintings, pamphlets, periodicals, photographs and photographic negatives, plans, press releases, promotional literature, prospectuses, purchase orders, receipts and other records of payments, records, reports, reports of X-rays or laboratory tests, research data, schedules, scrapbooks, sketches, speeches, statements, studies, summaries or records of any transaction or occurrence including, without limitation, conversations, interviews, meetings and conferences, summaries of any other document including, without limitation, reports of investigations and reports of negotiations, studies, surveys, tables, or tabulations of data, tracings, transcripts, telegrams, videotape, vouchers, workpapers and worksheets.  [NOTE: This list may be amended to reflect new technologies.]

The terms "you" and "yours," unless another intention clearly appears, refers to each party to whom this Request is made and any of their principals, agents, employees, attorneys, representatives, insurers, and any persons acting or purporting to act on their behalf, and any persons in active concert and participation with them, whether past or present, without regard to whether or not the relationship currently exists or has been terminated.

 The term "exempt" refers to those employees who are exempt from or under the Fair Labor Standards Act.

1. Each and every document .  .  .

                                   Respectfully submitted,
                                   PLAINTIFF, pro se

                                   __________________________________
                                   Your name, address, and phone