The topic of this video is what is a request to produce in a personal injury case. Now, if you have filed a lawsuit in a personal injury case, there is a discovery mechanism called a request to produce. And basically, all that is, is a written request for documents. It’s really as simple as that. And so if you filed a lawsuit, your lawyer will definitely send a request to produce to the defendant’s lawyer. And likewise, the defendant’s lawyer will send back a request to produce to you. Now, just because this is a personal injury case doesn’t mean that a request to produce is specific only to personal injury type cases. In fact, they’re common and standard in every single civil case, whether it be real estate contract, you name it, they’re done in every single type of case. So what specifically, uh, changes for a personal injury case will really only the types of questions that are asked. So what I did was I pulled together out of one of my other cases of sample request to produce that an insurance defense lawyer for a big insurance defense company sent to me. And so what I’d like to do is just simply read the request to produce that this insurance defense lawyer has asked my client to respond to in another case. And I’ll just go through one by one.
So the first one is a federal tax returns number two withholding statements. Number three, itemized medical bills. Number four, statements made by occupants of the automobile. It was a car accident. Case number five statements made by witnesses. Number six, statements made by the defendant. Number seven, photographs of the automobiles. Number eight, photographs depicting injuries. Number nine, photographs, photographs depicting injuries which no longer exists at the present time. Number 10, photographs of the scene. Number 11 photographs for use at trial. Number 12 documents regarding the repairs or damages to the car. Number 13 incident reports. Number 14 medical records from your treating and examining physicians. That’s a long one. They’re asking for a lot of subcategories there. Number 15 any and all medical records, surgery. 16 reports of nonmedical experts. Number 17 documents that show payments made to the plaintiff from various organizations. Number 18 collateral sources.
Any, any, uh, money received from any other sources? Uh, number 19, any, um, insurance documents on collateral sources, number 20 cell phone records from the time of the loss and 21 copy of the insurance card. So I said this is, this is standard in every personal injury case. You may not get these exact questions, but you’ll generally get some form of these types of questions and definitely exploring these types of areas. So what we do when we get a request to produce, no need to panic, we send it off to our clients, said, hey, anything that you have bring it in. Otherwise, like all the medical records, all the medical documents we’ll have in the office, we handle all that. It’s usually very easy for a client to respond to this. And basically, we do all the work, put together the documents and send it off. But again, this is standard in every single case, including personal injury cases. So that is a request to produce in a personal injury case. I hope this was helpful.
*The above has been transcribed by a third party service and has not been checked for accuracy.
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