Request for production

What is a request for production?

A request for production is a formal discovery tool used to compel the opposing party to produce specific documents, records or other tangible items relevant to the case.

Unlike a subpoena, which can reach non-parties, this specific tool is directed at the opposing party within the litigation itself rather than at outside witnesses or record holders.

It works alongside interrogatories as one of the primary methods for exchanging documentary evidence during the discovery phase of a case.

Responses generally must be provided within a specific period the applicable court rules establish, though extensions by agreement between counsel are fairly routine.

What is commonly requested in a personal injury case?

The specific categories requested vary by case type, but certain items appear consistently across most injury litigation.

• Complete medical records related to the claimed injuries
• Photographs and video related to the incident or the injuries
• Insurance policies and applicable coverage documents
• Maintenance records, inspection logs or similar operational documents
• Internal communications and incident reports
• Employment records relevant to wage loss or work capacity

What happens if the other side does not fully comply?

Genuine objections can be raised where a specific request is overly broad, seeks privileged material, or imposes a genuinely undue burden relative to its relevance.

Where objections are not legitimate, or where responsive documents are simply withheld without proper basis, a motion to compel can be filed asking the court to order compliance.

Courts can impose sanctions for improper non-compliance, which provides meaningful incentive for parties to respond appropriately to legitimate discovery requests.

Why does this tool matter so significantly to building a case?

Because much of the most valuable evidence, including internal company communications, maintenance records and incident reports, exists only within the opposing party's own possession and would otherwise remain entirely unavailable.

Comparing what a defendant's internal documents actually reveal against their public statements or testimony frequently produces some of the most significant evidence in a case.

This is precisely why thorough, carefully drafted requests, tailored to the specific facts of each case, matter so considerably rather than relying only on generic boilerplate language.

Common questions

Can the other side refuse to produce anything I request?

They can raise legitimate objections to specific requests, but cannot simply refuse without proper basis, and improper refusal can be challenged through a motion to compel.

How long does the other side have to respond?

Applicable court rules generally establish a specific response period, though extensions by agreement between the attorneys are fairly common in practice.

What if I receive a request for production from the opposing side?

Your attorney will help identify what must genuinely be produced, and legitimate objections can be raised where specific requests are improper or overly broad.