Request for Production

IN THE COURT OF COMMON PLEAS

XXXX

Plaintiff Irving XXXX, Inc. requests that Defendant City of East Cleveland file within thirty (30) days a written response to requests herein and to produce the requested documents for inspection and copying within thirty (30) days of service of this request at the offices of the Plaintiff, XXXX.  

1. Your written response shall state for each item, that inspection-related activities will be permitted as requested unless the request is refused. In that event, the reasons for refusal shall be stated. If the refusal relates to part of an item, that part shall be specified.
2. In accordance, the documents shall be produced as they are covered in the usual course of business, or you shall organize and label them to correspond with the categories in the request.
3. These requests shall encompass all items within your possession, custody, or control.
4. These requests are continuing in character to require you to promptly amend or supplement your response if you obtain further material information.
5. If in responding to these requests, you encounter any ambiguity in construing any request, instruction, or definition, set forth the matter deemed ambiguous in the construction used in responding.

Definitions

As used in these requests, the following terms are to be interpreted per these definitions:

1. The term “person” includes any individual, joint-stock company, unincorporated association, or society, municipal or other corporation, state, which agencies or political subdivisions, and court or any other governmental entity.
2. The terms “you” or “your” include the person(s) to whom these requests are addressed, and all that person’s agents, representatives or attorneys.
3. In accordance, the terms, “document” or “documents” includes all writings, drawings, graphs, charts, photographs, recordings, and any other data computations from which information can be obtained, translated, if necessary by (you), through detection devices, into a reasonably usable form.

Requests

1. Any Court order and/ or Certificate of Demolition that authorized the demolition of the Plaintiff’s property. 
2. The following Document Requests No. 1 through No. 9 refer to any person that you intend to call as an expert witness to testify at trial on behalf of the Defendant:

1. All written reports of each person whom you expect to call as an expert witness at trial.
2. The most recent resume or curriculum vitae of each expert whom you expect to call as an expert witness at trial.
3. All notes, diagrams, photographs, or other documents prepared or reviewed in connection with their assignment in this case by each person whom you expect to call as an expert witness at trial.
4. All drafts, working papers or documents generated by each witness whom you intend to call as an expert at trial in connection with the opinions and subjects on which the witness is expected to testify.
5. Each publication or paper that was written or worked on by each witness whom you intend to call as an expert witness at trial, and which refers or relates to the opinions and subjects on which the witness is expected to testify.
6. Any documentation at all upon which you intend to base in whole, or in part, any defense to the allegations set forth in the Plaintiff’s Complaint and response to your Counterclaim.
7. All documents, correspondence, or interoffice memoranda concerning the facts, matters, circumstances in the Complaint in the instant action.
8. All documents in support of any factual allegations and/or contentions contained in your Answer and Counterclaim filed in this case.
9. All documents You intend to introduce or rely upon at trial in this case not produced in response to the other requests.

Dated this _________ day of _____________.

___________________________

Attorney/Plaintiff

CERTIFICATE OF SERVICE

I hereby certify a copy of the foregoing has been served upon the Defendant’s counsel via [STATE MEANS OF SERVICE] to the address on record on this XXXX

___________________________

Attorney/Plaintiff

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