What is a “request for production of documents”?

A Request for Production of Documents, or RPD, is used in discovery as a formal way for one party to ask another party to hand over copies of any evidence in the form of documents related to the case. Along with interrogatories and requests for admissions, requests for production of documents are used to gather information about the case.

When a party is served with a request for the production of documents, she is obligated by law to find all of the documents enumerated in the request and turn those documents over to the other party unless the documents qualify for an exception. For instance, some requests cover information that is privileged, like communications between spouses, and some requests cover information that may not exist. To ensure that only the appropriate information is given to the other party and that it is turned over on time, attorneys usually review the documents their clients provide in response to a request for production of documents before forwarding them to the party making the request.

A typical request for production of documents contains several separate, numbered requests. These requests usually ask for a certain class or type of documents, but are broadly worded so as to cover as many documents as possible. For instance, a request for production of documents may ask for any documents related to insurance that covers the issue involved in the case. If the case is a personal injury claim filed by a party injured in a car accident, for example, the request for production of documents may ask for the declarations page, proof of financial responsibility, or even the entire car insurance policy the defendant had when the accident occurred. Other common requests made in a request for production of documents include:

  • Copies of any bills for medical care or repair of damaged property.
  • Contact information for every expert whose testimony the party may use at trial.
  • Copies of the resume or curriculum vitae (CV) of each of these experts.
  • Copies of medical records, including records from physical therapists, psychologists or counselors, or others who provided care for the injured person as a result of the injury involved in the case.
  • Copies of any written sources the attorney or expert plans to refer to in building his or her case.
  • Copies of any written statements made by the party, such as statements given to a police officer after a car crash.
  • Copies of insurance policies, bank statements, or other financial or business documents related to the case.
  • Copies of any audio or video recordings, photographs, x-rays, scans, or other multimedia items produced as part of the investigation of the case or the treatment of the injured plaintiff.
  • Copies of any documents the party referred to in its answers to the interrogatories, which are usually sent before or along with a request for production of documents.

The types of information asked for in a request for production of documents depend on the facts of the case. For instance, a request for production of documents in a car accident may ask for documents related to auto liability insurance, or for any pictures or diagrams of the place where the accident occurred. A request for production of documents in a medical malpractice case may ask for information about the physician’s or hospital’s credentials. Some requests, like the request for any documents referred to in the interrogatories, apply to almost every personal injury case, regardless of what happened.

 

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