REQUESTS FOR PRODUCTION - PERSONAL INJURY

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.

Definitions

• "Incident" means the event described in the complaint.
• "Document" includes paper records, emails, texts, photographs, videos, recordings, and electronically stored information.
• "You" means the responding party and any agents acting on your behalf.

Requests

1. All photographs, videos, or recordings of the Incident, scene, vehicles, or injuries.
2. All police reports, incident reports, or investigative materials related to the Incident.
3. All medical records and bills related to injuries claimed in this action.
4. All health insurance, Medicare, Medicaid, or benefit statements related to medical treatment.
5. All documents reflecting lost wages, including pay stubs, W-2s, 1099s, or employer statements.
6. All documents supporting claims of future medical treatment or future economic loss.
7. All documents reflecting prior injuries, medical conditions, or claims involving the same body parts.
8. All correspondence with any insurer regarding the Incident or claims.
9. All repair estimates, invoices, or receipts for property damage.
10. All social media posts, messages, or online content referencing the Incident or injuries.
11. All witness statements or recorded interviews concerning the Incident.
12. All documents reflecting lien or subrogation claims, including notices and payment demands.
13. All surveillance, dash-cam, or body-cam footage relevant to the Incident.
14. All expert reports, evaluations, or opinions regarding liability or damages.
15. All settlement agreements or releases related to the Incident.

Verification

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

______________________________
[RESPONDING PARTY NAME]
Date: [DATE]