Request for Production Model Products Liability Case 1

The plaintiff, pursuant to Rule [] of the Rules of Civil Procedure, requests that the defendant produce and permit the plaintiff to inspect, copy, and photograph the following documents and things which are in the defendant's possession, custody, or control:

1. Each sales slip, receipt, charge account statement, invoice bill, cancelled check, purchase order, lease, agreement, or other document which was issued or recorded because of the sale, purchase, or lease of the product.

2. With respect to each and every item described in the immediately preceding request which is not in the physical possession or custody of the defendant, but which is in the defendant's control, the plaintiff hereby requests that the defendant execute authorizations to allow the plaintiff to obtain and examine such items.

[3. Each and every sales slip, receipt, charge account statement, invoice bill, cancelled check, purchase order, lease, agreement, or other document which was issued or recorded because of the sale, purchase or lease of a component part of the product.]

[4. With respect to each and every item described in the immediately preceding request which is not in the physical possession or custody of the defendant, but which is in the defendant's control, the plaintiff hereby requests that the defendant execute authorizations to allow the plaintiff to obtain and examine such items.]

5. Each and every written, printed, or graphic representation, catalogue, statement, circular, manual, brochure, report, advertisement, or other document which was propounded by or on behalf of the defendant and which mentions, describes or otherwise refers to the virtues, qualities, characteristics, capabilities, or capacities of the product.

6. With respect to each and every item described in the immediately preceding request which is not in the physical possession or custody of the defendant, but which is in the defendant's control, the plaintiff hereby requests that the defendant execute authorizations to allow the plaintiff to obtain and examine such items.

As used herein, the phrase "other document" shall include all types of recorded information, including but not limited to, writings, drawings, graphs, charts, photographs, phonorecords, and all other data compilations from which information can be obtained or which, if necessary, can be translated through detection devices into reasonably usable form.

As used herein, the word " product " shall mean the product whose alleged defect has given rise to this litigation.

The plaintiff requests that the documents and things herein requested be produced at the office of the plaintiff's attorney, [here state the appropriate address] on the 28th day after service of this request.

The defendant may comply with this request by forwarding a copy of each document and thing requested to the plaintiff's attorney if such copies are postmarked prior to the date for which production has been designated in the preceding paragraph. The defendant is also requested to appropriately designate each document and thing produced so as to indicate the paragraph above pursuant to which each document and thing is produced. If a document or thing is produced pursuant to more than one paragraph, the designation should so indicate.