Below are plaintiffs’ sample answer to a request for production of documents in a dog bite case.
Civil Division
Plaintiff :
v. : CASE NO.: 24-C-14-001028 OT
MARGARET COLLINS, et al. :
Defendants :
REQUESTS FOR PRODUCTION OF DOCUMENTS
FROM: CAROL HANNISH, Plaintiff
REQUEST NO. 1: All medical records, surgical records, hospital records, clinic records, mental records, medical reports, writings, notes or memoranda relating in any way to the Plaintiff’s disabilities, including but not limited to those of doctors, nurses, practitioners, hospitals, clinics, institutions, or other health care providers or third party private or governmental health or accident insurers, without regard to whether it is the plaintiffs’ contention that such physical, mental or medical conditions, illnesses or disabilities were caused in any way by the Defendants or any agent or employee of the Defendants for the period of time commencing fifteen (15) years before the occurrence alleged in the Complaint up to and including the present date.
RESPONSE: Plaintiff objects to this request on the grounds that it is irrelevant and the discovery of which is not likely to lead to information which would be admissible at the trial of this matter. Without waiving said objection, Plaintiff agrees to comply with this request to the extent Plaintiff is in possession of documents identified. See Attached.
REQUEST NO. 2: All statements, bills, receipts, financial records or other written material which evidence any and all costs or expenses incurred as a result of the occurrence referred to in your Complaint.
RESPONSE: Plaintiff agrees to comply with this request. See Attached.
REQUEST NO. 3: Reports of all experts who are expected to testify at the trial of this case, including but not limited to all documents referring or relating to any findings or opinions of any person whom you intend to call as expert witness at the trial of this action, which findings or opinions relate to any alleged act of negligence by any person, or other liability in connection with the allegations contained in the Complaint.
RESPONSE: Plaintiff agrees to comply with this request to the extent Plaintiff is in possession of documents identified. See Attached.
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REQUEST NO. 4: All documents referring or relating to any admission or statements made by any representative of these Defendants relating to the allegations contained in your Complaint.
RESPONSE: None.
REQUEST NO. 5: All documents referring or relating to communications between you and these Defendants.
RESPONSE: Plaintiff agrees to comply with this request to the extent Plaintiff is in possession of documents identified. See Attached.
REQUEST NO. 6: All documents referring or relating to facts tending to support the allegations in your complaint.
RESPONSE: Plaintiff agrees to comply with this request to the extent Plaintiff is in possession of documents identified. See Attached.
REQUEST NO. 7: All documents referring or relating to any loss of time from your employment, business or occupation as well as any loss of income you have sustained as a result of the occurrence.
RESPONSE: None. Plaintiff is not making a claim for lost wages.
REQUEST NO. 8: Any and all income tax returns, schedules, W-2’s or 1099 forms, both State and Federal, for the five (5) years preceding the occurrence, and for each year subsequent, up to the present. If the documents are unavailable to you, please execute the attached 4506 and 4506-T tax forms and return to the party requesting this information.
RESPONSE: Objection. Plaintiff is not making a claim for lost wages.
REQUEST NO. 9: All documents referring or relating to any allegation that you have incurred medical or other related expenses as a result of the allegations contained in the Complaint.
RESPONSE: Plaintiff agrees to comply with this request. See Attached.
REQUEST NO. 10: All transcripts or recordings of the testimony of any person or persons relating to the injuries and damages for which claim is being made in this action.
RESPONSE: None.
REQUEST NO. 11: All documents referring or relating to any insurance coverage which you had which provided any benefits with respect to the injuries or damages allegedly sustained as a result of the allegations contained in your Complaint.
RESPONSE: Plaintiff agrees to comply with this request; however, no such documents exist.
REQUEST NO. 12: All documents referring or relating to any settlement, loan receipt, subrogation agreement, release, or similar agreement between you and any person or persons with respect to the allegations contained in your Complaint.
RESPONSE: Plaintiff agrees to comply with this request. See Attached.
REQUEST NO. 13: All documents referred to or identified in your responses to Interrogatories propounded by these Defendants.
RESPONSE: Plaintiff agrees to comply with this request. See Attached.
REQUEST NO. 14: All other documents which you claim support the contentions set forth in your Complaint.
RESPONSE: Plaintiff agrees to comply with this request. See Attached.
REQUEST NO. 15: All employment records relating in any way to the Plaintiffs, whether employed or self-employed, including the names and addresses of all employers, the records relating to the fact and duration of unemployment and all records of income from employment for the last ten years.
RESPONSE: Objection. Plaintiff is not making a claim for lost wages.
REQUEST NO. 16: All of Plaintiffs’ records of worker’s compensation, unemployment insurance, welfare, social security, disability, and applications for assistance from any governmental agency because of unemployment, disability or ill health for the last ten years.
RESPONSE: Plaintiff agrees to comply with this request; however, no such documents exist.
REQUEST NO. 17: With respect to any hospital records, doctors records, go
vernmental records or any other records referred to in this Request for Production of Documents which are in existence but are not physically in the possession or custody of the Plaintiffs or Plaintiffs’ attorneys, the Defendants request that the Plaintiffs produce executed authorizations for each doctor, hospital, person, corporation, agency, etc., where records exist, to allow the Defendants to examine and obtain copies of said records.
RESPONSE: Plaintiff objects to this request, as it is not a request to produce a document, rather an impermissible request to create a document.
REQUEST NO. 18: Any and all releases, settlement agreements, correspondence, or other documents, formal or informal, pursuant to which the liability of any person for any injury or damage arising out of the facts pertinent to the subject matter of this litigation has been limited, reduced or released in any manner.
RESPONSE: Plaintiff agrees to comply with this request, however no such documents exist.
REQUEST NO. 19: All notes, diagrams, photographs or other documents prepared or reviewed by each person whom you expect to call as an expert witness at the trial of this matter.
RESPONSE: Plaintiff agrees to comply with this request. See Attached.
REQUEST NO. 20: All draft, working papers, or documents generated by each witness whom you intend to call as an expert at the trial of this matter in connection with the opinions and subjects on which the witness is expected to testify.
RESPONSE: Plaintiff agrees to comply with this request to the extent Plaintiff is in possession of documents identified. See Attached.
REQUEST NO. 21: The most recent resume or curriculum vitae of each individual whom you expect to call as an expert witness at the trial of this matter.
RESPONSE: Plaintiff reserves the right to supplement this response as discovery is ongoing.
REQUEST NO. 22: All photographs, videotapes or audiotapes, x-rays, diagram, surveys or other graphic representations of information concerning the subject matter of this action.
RESPONSE: Plaintiff agrees to comply with this request. See Attached. Plaintiff also reserves the right to use demonstrative evidence at trial including but not limited to anatomical models, demonstrative medical illustrations, medical diagrams, and demonstrative animated video of Plaintiff’s injuries and/or demonstrative animated video of the Plaintiff’s medical treatment including but not limited to surgeries or other procedures performed in the past or expected to be performed in the future.
RESPONSE: None.
REQUEST NO. 24: Any and all documents or publications in your possession pertaining to or relating to injuries allegedly sustained by the Plaintiffs in connection with the occurrence.
RESPONSE: None.
REQUEST NO. 25: Any and all documents referring or relating to past or subsequent claims, actions or suits for personal injuries.
RESPONSE: Plaintiff agrees to comply with this request, however no such documents exist.
Respectfully submitted,
Miller & Zois, LLC
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