Request for Production of Documents Template – Free Download 2026

Pursuant to [Rule 34 of the Federal Rules of Civil Procedure / applicable state discovery rules], [Requesting Party] requests that [Responding Party] produce and permit inspection, copying, testing, and sampling of the following documents, electronically stored information ("ESI"), and tangible things within [30 / ____] days of service at the offices of [____________], or at such other time and place as the parties may agree. For purposes of these Requests, the following definitions apply: (a) "Document" means every writing, drawing, graph, chart, photograph, sound recording, image, and other data or data compilation, including ESI stored in any medium from which information can be obtained directly or, if necessary, after translation into a reasonably usable form; (b) "ESI" means electronically stored information, including emails, calendar entries, word processing documents, spreadsheets, databases, presentation materials, text messages, instant messages, and all associated metadata.

Each Request shall be construed to encompass all documents and ESI within the Responding Party's actual or constructive possession, custody, or control, including documents and ESI held by the Responding Party's employees, agents, attorneys, accountants, consultants, and any third-party vendors or cloud storage providers. The Responding Party shall search all reasonably accessible locations, including individual custodian files, shared drives, email servers, archived systems, backup media, and personal devices used for business purposes. If any responsive document has been destroyed, lost, or is otherwise unavailable, the Responding Party shall describe the document with as much particularity as possible and identify the circumstances of its unavailability, including the date of destruction and the identity of the person responsible.

REQUEST NO. 1: All documents and ESI concerning or evidencing [the contract, agreement, or understanding at issue in this litigation], including all drafts, versions, amendments, exhibits, attachments, and related correspondence. REQUEST NO. 2: All documents and ESI constituting, evidencing, or reflecting any communication between [Responding Party] and [____________] concerning [the subject matter of the litigation] from [____________] through the present. REQUEST NO. 3: All documents and ESI concerning or evidencing any payment, invoicing, billing, accounting, or financial transaction between [Responding Party] and [____________] from [____________] through the present.

REQUEST NO. 4: All documents and ESI that you intend to use in support of any claim, defense, or motion in this action, including all documents identified in your Initial Disclosures. REQUEST NO. 5: All documents and ESI concerning or evidencing any damages, losses, or harm allegedly suffered by [any party] as a result of the events alleged in the [Complaint / Counterclaim], including all financial records, loss calculations, invoices, receipts, and expert reports. REQUEST NO. 6: All documents and ESI concerning any investigation, audit, review, or analysis conducted by or on behalf of [Responding Party] regarding the matters at issue in this litigation, including all reports, memoranda, notes, and findings generated in connection with any such investigation.

Documents and ESI shall be produced in the following format: (a) hard-copy documents shall be scanned and produced as single-page TIFF images with an accompanying load file, maintaining the original document orientation and unitization; (b) ESI shall be produced in native format with full metadata, or in TIFF format with an accompanying metadata load file containing at minimum the following metadata fields: Bates Number, Custodian, Date Created, Date Modified, Author, Recipients, File Type, File Size, Original File Name, MD5 Hash, and Email Thread ID; (c) documents produced in native format shall be assigned a Bates number and accompanied by a placeholder TIFF image; and (d) all produced documents shall be labeled with sequential Bates numbers in the format [Producing Party Abbreviation]-[000001].

For any document or ESI withheld on the grounds of attorney-client privilege, work product protection, or any other applicable privilege, the Responding Party shall serve a privilege log concurrently with its production, identifying for each withheld document: (a) the Bates range or unique identifier; (b) the date of the document; (c) the identity and title of the author; (d) the identity and title of all recipients, including cc and bcc recipients; (e) a general description of the subject matter sufficient to assess the privilege claim without revealing the privileged information; and (f) the specific privilege or protection asserted. The Responding Party shall produce any document for which only a portion is privileged, with the privileged portion redacted and the redaction noted in the privilege log.