J. If any paragraph of this request is believed to be ambiguous or unduly burdensome,
please contact the undersigned and an effort will be made to remedy the problem.
DEFINITIONS
A. “Document” is used in the broadest possible sense and means, without limitation, any
written, printed, typed, digitized, photostated, photographic, computerized, recorded, or
otherwise reproduced communication or representation, whether comprised of letters, words,
numbers, pictures, sounds or symbols, or any combination thereof. It includes the original and
any nonidentical copies thereof, whether different from the originals by reason of any notation
made on such copies or otherwise, and includes every document that is or has been in the
possession, control, or custody of Defendant or of which Defendant has knowledge, whether
originals or copies. It includes but is not limited to contracts, notes, memoranda,
correspondence, diaries, desk or other calendars, statistics, letters, telegrams, minutes, business
records, personal records, account statements, reports, studies, checks, receipts, bills, returns,
charts, summaries, pamphlets, books, notations of any sort of conversations, written agreements,
bulletins, printed matter, computer printouts, electronic mail, data compilations from which
information can be obtained, teletypes, telefax, worksheets, logs, forms, bank statements, books
of account, ledgers, or invoices, all drafts, alterations, modifications, changes and amendments of
any of the foregoing, graphic or oral records or representations of any kind, including but not
limited to tapes, cassettes, discs, recordings, computer memories, and other information that is
recorded electronically, digitally, or by similar means.
B. The term “person” shall include a natural person, partnership, corporation, joint
venture, association, or other group however organized.
C. The term “transaction,” when used without qualification, means the transaction
consummated by the Plaintiff [date and description].
REQUESTS TO PRODUCE
IMPORTANT: All questions containing the terms “document,” “person,” or
“transaction” must be answered in accordance with the definitions of those terms contained in
the attached instructions.
REQUESTS FOR PRODUCTION
1. All contracts, including modifications thereto, to which Plaintiff is a party, including
any and all broker agreements.
2
2 In the alternative, this and the next five document requests can be replaced with a single request
such as “All documents pertaining to the credit transaction underlying this action, including but
not limited to the entire contents of the files and the inside and outside of the front and back of
the file folders for this transaction, all documents signed by defendant, disclosures, applications,
correspondence, work sheets, underwriting forms, file notations and any other document.”