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Legal Malpractice: Request for Production of Documents

IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND

AMY SMITH
– Plaintiff

v

STEVE MOORE, et al,
– Defendants

CASE NO.: 05-C-08-6561

Request for Production of Documents

Plaintiff hereby requests that Defendant Steve Moore file within thirty (30) days a written response to requests on the attached Document Schedule and to produce those documents for inspection and copying within thirty (30) days of service of this request at the Law Offices of Miller & Zois, LLC, 1 South St, #2450, Baltimore, MD 21202.

  1. Your written response shall state with respect to each item or category, that inspection-related activities will be permitted as requested, unless request is refused, in which event the reasons for refusal shall be stated. If the refusal relates to part of an item or category, that part shall be specified.
  2. In accordance, the documents shall be produced as they are covered in the usual course of business or you shall organize and label them to correspond with the categories in the request.
  3. These requests shall encompass all items within your possession, custody or control.
  4. These requests are continuing in character so as to require you to promptly amend or supplement your response if you obtain further material information.
  5. If in responding to these requests you encounter any ambiguity in construing any request, instruction or definition, set forth the matter deemed ambiguous in the construction used, in responding.

Definitions

As used in these requests, the following terms are to be interpreted in accordance with these definitions:

  1. The term “person” includes any individual, joint stock company, unincorporated association or society, municipal or other corporation, state, which agencies or political subdivisions, and court, or any other governmental entity.
  2. The terms “you” or “your” include the persons to whom these requests are addressed, and all that person’s agents, representatives or attorneys.
  3. In accordance, the terms, “document” or “documents” includes all writings, drawings, graphs, charts, photographs, recordings, and any other data computations from which information can be obtained, translated, if necessary by (you), through detection devices, into reasonably usable form.
  4. The term “occurrence” means the incident complained of in the Plaintiff’s complaint.

Requests

  1. All insurance policies under which a person carrying on an insurance business might be liable to satisfy all or part of a judgment that might be entered in this action or reimburse you for payments made to satisfy such a judgment.

The following Document Requests No. 2 through No. 6 refer to any person that you intend to call as an expert witness to testify at trial on behalf of the Defendant:

  1. All written reports of each person whom you expect to call as an expert witness at trial.
  2. The most recent resume or curriculum vitae of each expert whom you expect to call as an expert witness at trial.
  3. All notes, diagrams, photographs or other documents prepared or reviewed in connection with their assignment in this case by each person whom you expect to call as an expert witness at trial.
  4. All drafts, working papers or documents generated by each witness whom you intend to call as an expert at trial, in connection with the opinions and subjects on which the witness is expected to testify.
  5. Each publication or paper that was written or worked on by each witness whom you intend to call as an expert witness at trial, and which refers or relates to the opinions and subjects on which the witness is expected to testify.
  6. A list of cases that the expert has been involved in for the last 5 years.
  7. All books, calendars, diaries, day timers, computer generated case management soft ware information, or other similar compilations maintained for business or professional reasons from August 12, 2003 until the present which contain any and all references to the legal representation of the Plaintiff.
  8. Any documentation at all upon which you or your firm intends to base in whole, or in part, any defense to the allegations set forth in the Plaintiff’s legal malpractice Complaint.
  9. All documents or records related to you or your firms legal representation of the Plaintiff including, but not limited to, retainer agreements, employment contracts, file notes, correspondence, memoranda, pleadings, e-mails, etc.
  10. All documents, correspondence, or inter office memoranda concerning the facts, matters, circumstances or allegations of the underlying tort claim includied in the legal malpractice Complaint in the instant action.
  11. Each document evidencing any expenses you incurred on behalf of the Plaintiff.
  12. Each document or draft of a document representing all pleadings, motions, or discovery you or your firm prepared and/or filed on the Plaintiff’s behalf.
  13. Each document evidencing all attorney time expended by you or your firm on behalf of the Plaintiff.
  14. Each document reflecting any telephone conversations or telephone messages, notes, email, and all forms of informal communication, or notations made by, for or between you, your firm and the Plaintiff, or anyone else relative to the you or your firms’legal representation of Plaitniff.
  15. Any documents evidencing any communication with you and your firm or any other attorney regarding the allocation of responsibilities, fees, or break down of shared legal work and representation.
  16. Any documents evidencing any communication with you and your firm or any other any other attorney, witness, or potential witness or other party relative to you or your firm’s legal representation of the Plaintiff.
  17. All documents in support of any factual allegations and/or contentions contained in your Answer filed in this case or in any other parties Answers to Plaintiff’s Interrogatories.
  18. Any and all documentation regarding any legal research or analysis performed by you to determine the apporpriate statue of limitations and proper jurisdiction for the Plaintiff’s case.
  19. Please provide a copy of your complete physical file(s) regarding your representation of Plaintiff including the copy of any folder or redwell the file is contained in.
  20. Please provide a copy of your complete computer kept file(s) regarding your representation of Plaintiff including but not limited to case management software data or word processing data, if your office is a paperless office, please print out the hard copies of any documentation scanned in or stored electronically or digitally.
  21. Any and all documents You intend to introduce or rely upon at trial in this case not produced in response to the other requests.

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