Rhode Island State Court Request for Production of Documents
RHODE ISLAND STATE COURT REQUEST FOR PRODUCTION OF DOCUMENTS
STATE OF RHODE ISLAND — SUPERIOR COURT
County / division: [________________________________]
C.A. No.: [________________________________]
| Party | Role |
|---|---|
| [PLAINTIFF NAME] | Plaintiff |
| v. | |
| [DEFENDANT NAME] | Defendant |
[REQUESTING PARTY]'S REQUESTS FOR PRODUCTION TO [RESPONDING PARTY]
To: [RESPONDING PARTY AND COUNSEL]
Under R.I. Super. R. Civ. P. 34, [REQUESTING PARTY] requests that [RESPONDING PARTY] produce or permit inspection, copying, testing, or sampling of the items described below that are in its possession, custody, or control and within Rule 26(b)'s discovery scope.
Requested inspection or production date: [__/__/____], subject to the response period in Rule 34(b)(2) or a different time allowed by the court.
Reasonable place and manner: [ADDRESS OR ELECTRONIC DELIVERY METHOD, ACCESS ARRANGEMENTS, AND PERSON TO CONTACT]
ESI format requested, if any, by category: [FILE TYPE / REQUEST NUMBER / REASON FOR FORMAT; OMIT IF NONE]
DEFINITIONS AND RESPONSE INSTRUCTIONS
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Relevant period: [START DATE] through [END DATE]. Each request is limited to the identified transaction, event, claim, or defense and the period stated in that request.
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Documents and ESI: The terms cover the writings, recordings, images, data, and tangible items described in Rule 34(a). A request reaches only items within the responding party's possession, custody, or control.
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Responses and objections: Serve a written response to each item or category stating whether the requested inspection, copying, testing, or sampling will be permitted. State the reasons for an objection; if only part of an item is objected to, identify that part and permit inspection of the rest, as Rule 34(b)(2) provides.
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Production organization: Produce documents as kept in the usual course of business or organize and label them to match the request categories under Rule 34(b)(3).
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ESI format: If a requested format is objected to, or none is specified, state the production format for each type of ESI under Rule 34(b)(4). Unless the parties agree or the court orders otherwise, ESI without a specified format may be produced in its ordinarily maintained format or another reasonably usable format. The same ESI need not be produced in more than one format.
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Privilege or trial-preparation claim: For information withheld on either ground, make the claim expressly and describe the nature of the withheld information sufficiently for other parties to assess the claim without revealing protected information, as Rule 26(b)(5) requires. A schedule with dates, authors, recipients, general subjects, and asserted grounds is requested if useful to explain the claims; the rule does not prescribe those fields for every item.
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Later information: Supplement a response when Rule 26(e)'s stated circumstances create a duty to do so.
REQUESTS FOR PRODUCTION
Retain and tailor only the requests relevant to the claims, defenses, and facts of this action. Identify each category with reasonable particularity.
Request No. 1. Produce the contract, amendments, and communications between [IDENTIFIED PARTIES] concerning [SPECIFIC AGREEMENT OR TRANSACTION] during [DATE RANGE].
Request No. 2. Produce records of performance or nonperformance of [SPECIFIC OBLIGATION] under [IDENTIFIED AGREEMENT] during [DATE RANGE].
Request No. 3. Produce communications between [IDENTIFIED CUSTODIANS] concerning [SPECIFIC EVENT OR ISSUE] during [DATE RANGE], including responsive email and messages.
Request No. 4. Produce the invoices, payment records, and account entries that support or contest [IDENTIFIED DAMAGES OR PAYMENT ISSUE] for [DATE RANGE].
Request No. 5. Produce photographs, recordings, measurements, and diagrams depicting [SPECIFIC INCIDENT, PROPERTY, OR CONDITION] taken between [DATES].
Request No. 6. Produce nonprivileged incident, inspection, or investigation records concerning [SPECIFIC EVENT] prepared or received by [IDENTIFIED UNIT OR CUSTODIAN] during [DATE RANGE].
Request No. 7. Produce nonprivileged policies, manuals, or instructions in effect on [DATE] governing [SPECIFIC PRACTICE AT ISSUE].
Request No. 8. Produce records showing [SPECIFIC REPAIR, NOTICE, OR REMEDIAL ACTION] related to [PROPERTY OR EVENT] during [DATE RANGE].
Request No. 9. Produce the identified electronically stored information concerning [SPECIFIC ISSUE] from [IDENTIFIED CUSTODIANS OR SYSTEMS] during [DATE RANGE], in [REQUESTED FORMAT, IF ANY].
Request No. 10. Produce the agreement, endorsement, or coverage document under which [IDENTIFIED INSURER] may satisfy or reimburse a judgment concerning [CLAIM OR EVENT], to the extent discoverable under Rule 26(b)(2).
Request No. 11. Produce nonprivileged records that [RESPONDING PARTY] identified in [SPECIFIC PLEADING OR RESPONSE] as support for [IDENTIFIED FACTUAL ALLEGATION OR DEFENSE].
Request No. 12. Produce [SPECIFIC ADDITIONAL CATEGORY], limited to [IDENTIFIED ISSUE, CUSTODIAN OR LOCATION, AND DATE RANGE].
RESPONSE TIMING
Rule 34(b)(2) generally calls for a written response within 40 days after service of the request. A defendant may respond within 60 days after service upon that defendant of the summons, complaint, Language Assistance Notice, and all other required documents. The court may allow a shorter or longer period. Rule 6(d) adds one day to a prescribed period measured after service of a paper that was served electronically or by mail. The actual response date here, taking account of the service method and any court order, is [__/__/____].
SIGNATURE
Signature: ________________________________________
Printed name: [________________________________]
Rhode Island Bar number (if attorney): [________________________________]
Address: [________________________________]
Telephone: [________________________________]
Email: [________________________________]
Counsel for: [________________________________]
Date: [__/__/____]
CERTIFICATE OF SERVICE
I certify that on [__/__/____] I served these requests on the following persons by the methods identified:
| Recipient | Counsel or unrepresented party | Address or EFS recipient | Method |
|---|---|---|---|
| [________________________________] | [________________________________] | [________________________________] | [________________________________] |
| [________________________________] | [________________________________] | [________________________________] | [________________________________] |
☐ Served through the Rhode Island Judiciary EFS. The electronically served document is available for viewing or downloading from the EFS.
☐ Served conventionally because this discovery does not lend itself to electronic service or the recipient is not a registered user. The method and proof are identified above.
Signature: ________________________________________
Printed name: [________________________________]
Date: [__/__/____]
SOURCES AND REFERENCES
- Rhode Island Superior Court Rules of Civil Procedure (February 2024): https://www.courts.ri.gov/Courts/superiorcourt/Documents/SuperiorCourtRulesOfCivilProcedure.pdf
- Rhode Island Supreme Court Article X, electronic filing: https://www.courts.ri.gov/Courts/SupremeCourt/Documents/Supreme-Rules-Article10.pdf
About this template
- Last updated
- October 3, 2026
- Citations checked
- October 3, 2026
- Jurisdiction
- Rhode Island
- Category
- Litigation & Court Documents
Legal authority
- R.I. Super. R. Civ. P. 26(b)(1)-(2), (b)(5) (discovery scope, insurance agreements, and privilege claims)
- R.I. Super. R. Civ. P. 26(e) (supplementation of responses)
- R.I. Super. R. Civ. P. 34(a)-(b) (party production requests and responses)
- R.I. Super. R. Civ. P. 5(b), (d) (service and ordinary nonfiling of discovery requests)
- R.I. Super. R. Civ. P. 6(d) (additional day after electronic or mail service)
- Rhode Island Supreme Court Article X, Rule 6(a), (d)-(e) (discovery service and certificate)
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
A reviewer verified this template's legal citations against the official source on October 3, 2026.
R.I. Super. R. Civ. P. 26(b)(1) (checked October 3, 2026): "Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action"
R.I. Super. R. Civ. P. 26(b)(2) (checked October 3, 2026): "A party may obtain discovery of the existence and contents of any insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment"
R.I. Super. R. Civ. P. 26(b)(5) (checked October 3, 2026): "the party shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the applicability of the privilege or protection."
R.I. Super. R. Civ. P. 26(e) (checked October 3, 2026): "A party is under a duty seasonably to amend a prior response if the party obtains information upon the basis of which"
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