This sample request for production of documents for a California divorce case has 36 separate categories for which documents are to be produced.

1. 1 Any Party
Any Street
2 Any Town, CA 55555
3 714-555-5555
4 Petitioner, In Pro Per
5
6
7
8
Superior Court of the State of California
9 County of ___________
10
11 In re the marriage of: ) Case No.
)
12 Petitioner: _________________________ ) Request for Production of Documents, Set One
)
13 and )
)
14 Respondent:____________________________ )
)
)
15
)
)
16
)
)
17
18 To subscribe to my FREE California weekly legal newsletter visit
19
http://www.legaldocspro.net/newsletter.htm and enter your e-mail
20
21 address. Be sure to remove this notice and all other notices before
22
23
using this document.
24 1PROPOUNDING PARTY: PETITIONER, ______________________________
25 RESPONDING PARTY: RESPONDENT, ____________________________
26
SET NUMBER: ONE
27
TO: RESPONDENT ____________________ AND HER ATTORNEYS OF RECORD:
28
- 1 -
REQUEST FOR PRODUCTION OF DOCUMENTS

2. 1 Petitioner, __________________________ hereby requests that you produce for
2 inspection and copying, pursuant to Section 2031 of the California Code of Civil Procedure, the
3 documents described below.
4 1 Such production, inspection, copying and/or photocopying shall take place at YOUR
5 ADDRESS, CITY, STATE, ZIP within thirty (30) days from date of service of this request,
6 thirty fve (35) days if served by mail, and shall continue from day to day, weekends and holidays
7
excepted, until completed. True, accurate and genuine copies of said documents may be forwarded to
8
the propounding party prior to the date of appearance in satisfaction of said notice. Moreover,
9
pursuant to this Code, the responding party is required to serve a written response, under oath, to this
10
11 Demand within 30 days after service. The response shall identify the documents falling within the
12 category specified and that inspection and related activities will be permitted as requested, unless the
13
request is objected to, in which event the reasons for objection shall be stated.
14
1I.
15
16 DEFINITIONS
17 1. As used herein, the terms "you" and "your" shall mean Respondent___________.
18
2. The term "writing" shall refer to letters, words or numbers, or their equivalent, set
19
down by handwriting, typewriting, printing, photocopying, photographing, magnetic impulse,
20
mechanical or electronic recording, or any other form of data compilations.
21
22 3. As used herein, the term "document" shall include all memoranda, writings, as
23 defined in Paragraph 2 above, notes, entries, summaries, letters, telegrams, telexes, cables, bulletins,
24
circulars, tapes, records, photographs, diagrams, computer printouts, computer tapes, software disks,
25
and all other printed, typewritten and handwritten matter, and electronic or other recordings, whether
26
the original, or any carbon or photographic, bookkeeping records, accounting records, canceled
27
28 checks, cashier’s check copies, receipts money order copies, wire transfers, loan payment receipts,
- 2 -
REQUEST FOR PRODUCTION OF DOCUMENTS

3. 1 letters, bills, invoices, computer printed data, ledgers, accounts payable journals, and documents
2 evidencing payments such as bank statements or other copy, production or facsimile thereof
3
4. The term "person" includes natural persons, partnerships, limited partnerships,
4
5 limited liability companies, associations, corporations, governments, including all instrumentalities,
6 officers, agents and subdivisions thereof, trust funds, unincorporated syndicates and all other business
7 and artificial entities.
8
15. As used herein, "person" refers to and includes natural persons, as well as
9
10 businesses and all other artificial entities, unless otherwise limited herein.
11 6. If any claim of privilege is asserted with respect to any document responsive to
12
any of the requests herein, identify each such document responsive to any of the requests herein,
13
identify each such document by stating the following information with respect to each such
14
document:
15
16 (a) The description of the subject matter of such document with sufficient particularity to
17 enable the same to be identified;
18 (b) The dates of preparation and sending of the document and the date, if any, appearing on
19
such document as the date thereof;
20
(c) The identity of each person who signed, prepared or sent the document, including his or
21
22
her full name, his or her present or last known residence address and telephone number, his or
23 her present or last known business address and telephone number, his or her employer's
24 name, and his or her position of employment, including titles of employment;
25
(d) The identity of each person who originated, circulated or published such document, or on
26
whose behalf such document was signed by the signer of behalf of a person other than the
27
signer;
28
- 3 -
REQUEST FOR PRODUCTION OF DOCUMENTS

4. 1 (e) The identity of each person who originated, circulated or published such document, or on
2 whose behalf such document was originated, circulated or published;
3
(f) The name and address of each person who was an
4
addressee thereof, or to whom such document was sent; and
5
6
(g) The identity of each person having custody of such document or any carbon, reproduction
7 or facsimile thereof.
8 (h) The Privileged claim.
9
7. If any document responsive to any of the requests therein has been destroyed,
10
discarded or lost, separately identify each such document by stating the following information with
11
respect thereto:
12
13 (a) The title and description of the subject matter of each document;
14 (b) The date, or approximate date, of the preparation and, if applicable, the sending of such
15
document;
16
(c) The identity of the person who destroyed, discarded or lost such document;
17
(d) The date, or approximated date, such document was destroyed, discarded or lost;
18
19 (e) A description of the circumstances under which such document was destroyed, discarded
20 or lost;
21
(f) The identity, if known, of each person who originated, circulated, published or received
22
such document;
23
(g) The identity of each person known or believed to have a copy of all or any portion of such
24
25 document.
26 The documents to be produced are as follows:
27
28
- 4 -
REQUEST FOR PRODUCTION OF DOCUMENTS

5. 1 1III.
2
CATEGORIES OF DOCUMENTS TO BE PRODUCED
3
UNLESS OTHERWISE INDICATED, THE FOLLOWING DOCUMENTS ARE TO
4
BE PRODUCED FOR THE PERIOD FROM _____________________ TO THE DATE OF
5
6 PRODUCTION SPECIFIED HEREIN.
7 (It is suggested that you request documents from the date of marriage
8
to the date of production. The more documentation you receive the more
9
10 information you have. And the more information you have the better. That
11
will help in preparing for trial or reaching a settlement. For each category
12
13 below that has a blank line put in the date or dates that you want documents
14
from. For tax returns you should ask for at least the last three (3) years,
15
16 same thing for other financial records. Remember that the more documents
17
you receive the better!)
18
19 1. TAX RETURNS:
20 Years Requested: _______________________________
21
a. This includes all attachment and supporting schedule/statements for the Federal
22
Tax returns, the California Tax returns and any tax returns filed in any other state or country.
23
b. Copy of Department of the Treasury Internal Revenue Service Form W-2 covering
24
25 wages paid to you for the period from ___________________ to the date of production specified
26 herein.
27
c. Copies of Federal and State Income tax returns filed by you together with
28
- 5 -
REQUEST FOR PRODUCTION OF DOCUMENTS

6. 1 To download and purchase the entire document visit:
2 http://www.scribd.com/doc/25882576/Sample-Request-for-Production-of-Documents-for-California-
3 Divorce
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 6 -
REQUEST FOR PRODUCTION OF DOCUMENTS

7. 1 To download and purchase the entire document visit:
2 http://www.scribd.com/doc/25882576/Sample-Request-for-Production-of-Documents-for-California-
3 Divorce
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 6 -
REQUEST FOR PRODUCTION OF DOCUMENTS

8. 1 To download and purchase the entire document visit:
2 http://www.scribd.com/doc/25882576/Sample-Request-for-Production-of-Documents-for-California-
3 Divorce
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 6 -
REQUEST FOR PRODUCTION OF DOCUMENTS

9. 1 To download and purchase the entire document visit:
2 http://www.scribd.com/doc/25882576/Sample-Request-for-Production-of-Documents-for-California-
3 Divorce
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 6 -
REQUEST FOR PRODUCTION OF DOCUMENTS