REQUESTS FOR PRODUCTION - CONTRACT AND COMMERCIAL

Instructions

1. Produce the documents described below within the time allowed by applicable rules.
2. If any responsive document is withheld, state the basis and identify the document by type, date, and author.
3. If no responsive documents exist, state so in writing.

Requests

1. The Agreement and all amendments, addenda, and change orders.
2. All communications concerning negotiation, formation, or execution of the Agreement.
3. All purchase orders, invoices, statements, or payment records.
4. All documents reflecting performance, delivery, or acceptance of goods or services.
5. All notices of default, cure, or termination.
6. All internal documents regarding the dispute, including memos or reports.
7. All documents supporting your claimed damages or offsets.
8. All documents relating to mitigation efforts.
9. All documents reflecting warranty claims or defect notices.
10. All documents identifying third-party vendors or subcontractors.
11. All documents relating to insurance coverage for the claims.
12. All documents you intend to rely upon in support of your claims or defenses.

Verification

text
I declare under penalty of perjury that the foregoing responses and productions are true and correct.

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]