REQUEST FOR PRODUCTION 1- Model for Car Accident Case

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REQUEST FOR PRODUCTION

To [name of defendant], defendant, and [name of defendant's attorney], attorney for defendant:

In accordance with the provisions of [cite relevant statute or rule], you are hereby requested to produce and identify the writings and other things as described by Exhibit [specify, such as: A], which is attached and incorporated by reference. You are requested to produce such writings and/or other things as requested in person, unless permission is granted in writing by plaintiff's counsel, at [time], on [date], at plaintiff's counsel's offices, located at [address].

Dated: [date].

[Signature and address]

Exhibit [specify, such as: A]

1. Copy of defendant's driver's license, and any and all amendments, renewals, or restrictions.

2. Copy of defendant's insurance policy or policies providing coverage for this incident as alleged, in their entirety, not just the face sheets of such policy or policies.

3. Copy of all ownership and registration papers belonging to the subject vehicle as described in the complaint as defendant's vehicle, including registration certificates, and so forth.

4. Copies of all reports or other writings obtained from any insurance indexing system or insurance reporting system that may have information regarding any alleged prior claims of plaintiff, if any in fact exist.

5. Copies of all witness statements obtained prior to the filing of this litigation by insurance agents, employees, or adjustors acting on behalf of defendant's insurance carrier.

6. Copies of any and all tickets or citations received as a result of this incident by defendant, if any.

7. Copies of all photographs depicting any damage to plaintiff's vehicle, defendant's vehicle, location of incident alleged, or cause or causes of the incident alleged.

8. Copies of all writings in support of your denial of liability as alleged in your answer on file in this action.

9. Copies of all writings in support of each of your affirmative defenses as alleged in the answer on file in this action.

10. Copies of all writings supporting your contention that plaintiff was contributorily negligent in some manner and that such contributory negligence caused in whole or in part or contributed in some manner to the nature and extent of the incident.

11. Copies of all writings disputing in whole or in part the extent, scope and nature of plaintiff's present medical condition or extent and scope of the damages alleged as a result of the subject incident.

12. Copies of any photographs, movies, and/or videotapes made of plaintiff at any time since the date of the incident alleged for any reason whatsoever.

13. Copies of any and all writings disputing in whole or in part any of plaintiff's claims for property damage to [his][her] vehicle as alleged in the complaint and disclosed thus far to defendants.

14. Copies of any and all writings disputing in whole or in part any of plaintiff's claims for loss of employment, loss of wages, employment benefits, or employment opportunities.

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