REQUESTS FOR PRODUCTION - EMPLOYMENT

Requests

1. All employment agreements, offer letters, and job descriptions.
2. Personnel file, including performance reviews and disciplinary records.
3. Employee handbook and policies in effect during Plaintiff's employment.
4. Records of complaints, investigations, or corrective actions related to Plaintiff.
5. Payroll records, time records, and wage statements.
6. Communications concerning Plaintiff's employment, discipline, or termination.
7. Documents relating to alleged comparators or similarly situated employees.
8. Records of training on discrimination, harassment, and retaliation.
9. Documents relating to damages or mitigation (job search records).
10. Communications with EEOC or state agencies, including charge files.

Verification

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

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]