Request for Production of Documents

Jordan Rossi is a Paralegal at DHHW.  She has worked with Dragga, Hannon, Hessler & Wills since 2012.

During the course of your case, you will engage in discovery, which is exactly what it sounds like, the discovering and disclosing of information about the opposing party.  This includes the answering of questions and exchanging of information by way of a document production. 

The exchanging of documents starts when receiving a written Request for Production of Documents.  Each party is allowed to request documents from the other, and Maryland Rules have not imposed a limit on how many requests may be asked of a party, within reason.  Providing the documents to the opposing side is known as the Response to Request for Production of Documents, and contains a written portion as well as the documents themselves.  You have 30 days from service of the Request for Production of Documents to gather what is requested so it can be provided to the opposing side. 

At first glance, these document requests can appear daunting.  The easiest way to go about gathering the documents it to take the requests one at a time, making a note of things you do and do not have, things that simply do not exist, and things you can obtain, like downloading bank and/or credit card statements via accessing your accounts online.  This will give you a better sense of what you have and help streamline your gathering process.  If you have paper copies of documents, gather them in a stack and write the request number on a piece of paper and stick that on top of the corresponding documents, for example, “Request No.1, Tax Returns.”  This will help keep you organized as you go.  If your record keeping is all electronic, you can provide them to us in a number of ways – which we will discuss with you - we will take care of all the sorting and organizing for you.  Because we produce documents as PDFs, providing us documents in PDF format is preferred because it saves us time in the long run.  We bates number documents, which is a numbering system giving each document a unique number and used to keep track of what was produced by which party.

When it comes to communications, gathering emails and text messages can be time consuming, but we can help with software to download certain communications directly from your device. 

While gathering documents can feel tedious and overwhelming, the burden is not on you alone.  The opposing party will have to do the same.

If you are overwhelmed and don’t know where to start, don’t worry, your attorney and paralegal are here for you.  We are happy to have a phone call, or exchange emails with you to go over the requests, identify the ones you don’t have and can’t get, and then make a list for you detailing where you should put your focus first.  Additionally, if you do have online access to your bank and credit card accounts, but need some help in downloading, we are happy to assist you, along with the organization of same.  Don’t panic if your online records only go back 4 years and the request asks for 5.  Your Response for Request for Production of Documents is not a onetime thing.  You are required and entitled to update your documents as many times as needed to provide new documents and those that you obtain over the course of your case.  So, if you know you have a specific document but it is in storage, in a safe deposit box, or just in your file cabinet and you can’t put your hands on it right now, don’t worry, we can provide it at a later date.     

Contributors:  Jordan Rossi, Paralegal, and Lindsay Parvis, Esquire, Partner


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