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Lnstructions / Discraimer Documents, Or the Comprehensiveness of The

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Lnstructions / Discraimer Documents, Or the Comprehensiveness of The REQuEsrFoR PRoDUcloN oF DocuMENTs- lnstructions / Discraimer Once a civillawsuit is commenced,a pafi is permittedto seekto obtaininformation relevant to the lawsuitabout other parties to the suit, during the fact-findingpnase Ueioretrial called !is9o1eV. Generalprovisions goveming Discoverylre found in Rul-eZO ot tne NevadaRules of CivilProcedure ('NRCP"). ln general,pirties mayobtainDiscovery about any matterwhich is relevantto the subjectmatter involved in the pendingaction, so long as the informationis privileged. not Informationabout each of thedifferent Disc.-overy tools avaiiable to partiesto a tawsuit, andhow they may be used,can be foundin NRCp30 thr;ugh36. Requestfgr Productionof Documentsis a discoverytool encompassed in Rule 34, and allows any partyto serve upon any other partya requestto producereievant documents. The party makingthe request(or someoneacting on the requesiingparty's behalf) is permittedto inipeit and copyany designateddocuments. "Documenis" include writings, drawings, graphs, charts, photographs,phonorecords, and otherdata compilationsfromwhicliinformatioi Gn 6e obtained, translated,if necessary,by the respondingparty through detection devices into reasonably usable form. Requestfor Productionof Documentsmay be served upon tfe plaintiffafter the lawsuitis commenced;and uponany other pafi onlyat the timeof or afterthat party is servedwith the summonsand complaint. The party upon whom the Request is served is ihen required to provide a wriftenresponse within thirty (30) days afterservice of the Request.A shorteror longertime may be orderedby the Courtor, in absenceof a Courtorder, agieed to by writtenstipul-ation of the parties,so longas the timeby whichresponse is extendeddoes not interferewit'h any time setfor completionof discovery(see, Rule29). Thepafi reguestingthatdocumenb be copied must pay the reasonablecost therefor, andthe Courtmay direct the respondingparty to lopy the documents. P.rovided[below].are sample Requests for Productionof Documentswhich may assistyou in discoveringcertain importantinformation about other parties that will be helpfulto your case. TheseRequests are fundamental in nature, and are not intended to bean all-inclusive compilation of whatyou may needto knowin orderto proveyour entirecase. DISGLAIMER:THE COURTDOES NOT G|VE LEGALADVTCE lf you need assistance in determining the applicability of any Request for Documents,or the comprehensivenessof the sample Requests provioeo below to yourcase' you areencouraged to obtainthe advice of a legalprofessional licensed to practice in Nevada, Professionallegal advice may also be of assistanceto you concerning the use of any of the other forms of discoverableinformation provided for in Court Rules30 through36. Pleaseuse only those Requestsfor Production of Documentsthat apply to the particulars of your own case,e'9. those that witl enabteyou to discoverto informition you will need to prove the facts of your case. Not every Requestapplies to every type of case or set of circumstances,and the coun may not requirean opiosing partyto complywith someor all of your document requests if they do not apply to the ficb oi your case. Reouestfor Productionof Documents: Pursuantto NevadaRule of civil Procedure34, "Documents" include writings, drawings, graphs, charts,photographs, phonorecords, and other data compilations from whijh informationcan be obtained,translated, if necessary,by the respondingparty through detection devices into reasonablyusable form. 1' Pleaseproduce the Documenlsin yourpossession, custody or controlwhich support your responsesto the Interrogatoriesserved concurrenfly herewith. 2. Pleaseproduce the Docume-ntsin yourpossession, custody or controlwhich support your responsesto the Requestsfor Admissionserved concurrenfly herewith. Pleaseproduce the Documents in your possession, custody or controlwhichsupport each affirmativedefense which you haveasserted in your Answei to the complaintagainst you. Designatewhich particular defense or defeniesyou claimeach documeniproduced appliesto. 4. Pleaseproduce the Documents in your possession, custody or controlwhichyou contend supporteach allegationin your complaint. Designatewhich particularallegation or allegationseach document produced applies to. 5. Pleaseproduce the Documents in your possession, custody or controlwhich support your claimeddamages. 6. Pleaseproduce the Documents in your possession, custody or controlwhich support your claimfor physical,mental, or emotionalinjuries. 7. Pleaseproduce the Documentsin yourpossession, custody or controlwhichsupport each contentionwhich you are making that someone other than you is responsible,inwhole or in part,for the damagesasserted in the Complaint. 8. Pleaseproduce a copyofany andall insurancepolicies and/or declaration sheets ofany and all policies,including excess umbrella policies, providing the natureand monetary amountsof all insurance and indemnity coverage for you and any named insured regarding the insuredof the vehiclethat causedinjuries and damagesto the Plaintiffin thelubject incident. 9. Produceproof of ownershipand/or any leaseagreement or otherdocumentary evidence regardingusage of the Defendant'svehicle in effectat the time of the incideni. 10. Produceany and all videotapes(including surveillance), charts, plats, drawings, laser copiesof or actualphotographs (e.g. in color),or otherwiseof: (a)any vehicle iniolved in the subjectincident; (b) any partyto thisaction, plaintiff, defendant, and/or witness; and (c) the sceneand/or surrounding area where subject incident occurred. 11. Producecopies of all writtenand/or audiotapes of any recordedstatement of eitherparry and/ornon-party witnesses as to either(a) howthe accidentoccurred and/or (b) the extent of injuriesand damages sustained by plaintiff. 12. Producecopies of all investigativereports, including accident reconstructionist reports, engineerreports, medical examination reports, medilal recordsreview, reports prepared by or on behalfof Defendantby eitherDefendant's auto liability insurer anblor iti agents, accidentreconstructionists, engineers, medical professionali, or otherwise,as to the causationof the underlyingincident and/or plaintiffs injuries and damagesarising therefrom. 13. Producecopies of all estimatesof repair,auto bodyinvoices of repairand other related recordsas to all injuriesand damageswhich occuired in the incidentas to all persons' property. 14. For eachexpert witness you expectwill testifoat trial,or any hearingrelated to this case, pleaseproduce a copyof their curriculumvitie and a completecofy of theirfile relating to thiscase. 15. Produceany and all documentsregarding Defendant's traffic and/or other law violation citationas a resultof this incident,including but not limitedto the citation,receipt of payment,court transcripts and printouts,and proofof disposition..
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