Requests for Production of Documents are part of the pretrial discovery portion of a lawsuit.

Under Maryland law, parties can send Requests for Production of Documents to the other party seeking documents or objects that concern issues in the case.

When I file a new suit on behalf of my injured client, I routinely serve Requests for Production of Documents on the defendant. This way, I get the defendant’s relevant documentation as soon as possible.

After the suit papers are served on the defendant, you can expect the defendant’s lawyer to send Requests for Production of Documents to you. Normally, the defense counsel also sends Interrogatories at the same time.

These are some of the things you will be required to produce in your Maryland accident and injury case . . .

  • The medical records that concern treatment you have received for the injuries that you sustained in your accident.

  • The medical bills for your treatment.

  • Any accident report that was prepared.

  • Any written statement(s) that you have made or witnesses have given you about the accident.

  • Documentation of any lost income that you claim.

  • Your tax returns for the past several years, if you are claiming a loss of income.

  • Your pre-accident medical records for the past 5 or 10 years.

  • Any exhibits that you will introduce into evidence at trial.

As a result of my investigation and case preparation, I will have most of the documents that must be produced, but there may be other documents or things that you will have to gather for me.

If the defense asks for documents or objects that we are not required to produce, and we cannot negotiate an agreeable alternative with defense counsel, we will file a Motion for Protective Order asking the Court to rule that we do not have to produce that documentation.

Documents must be produced within time limits established by the rules of procedure, and if you don’t comply with the time limits, serious penalties can be imposed against you, even including, in extreme cases, dismissal of your case.

So, as with all other discovery, document productions require your immediate and conscientious attention.

If you have questions about production of documents, please contact me.