PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
OF DOCUMENTS AND PROPERTY
The plaintiff, NAME, acting thorough counsel, Philip J. Santa Maria, requests, pursuant to the authority of Maryland Rule 2-422, that the defendant, DEFENDANT, produce the following items that are in the defendant’s possession, custody or control and allow the party making this request to inspect and copy the following designated documents and to inspect and copy, test, or sample the following designated tangible things:
1. All photographs, drawings or other depictions of the accident scene.
2. All photographs or other depictions of the damage that your motor vehicle sustained as a result of this occurrence.
3. All photographs or other depictions of the damage that the Plaintiff’s motor vehicle sustained as a result of this occurrence.
4. All other documents or tangible things which you contend relate, in any way, to the happening of the occurrence or the damages caused by it. This request includes, but is not limited to, all photographs, videotapes, or other photographic depictions of the Plaintiff.
5. All documents or tangible things which you intend to introduce into evidence at any hearing or trial in this case.
6. All reports, memoranda or other written documents, made by you or received by you in the regular course of business, which concern the happening of the occurrence.
7. Your automobile liability insurance policy that was in effect at the time of the occurrence.
8. All documents obtained by you or provided to you through discovery, including by subpoena.
9. All reports from experts that you intend to call as witnesses at trial.
10. A curriculum vitae for each expert that you intend to call as a witness at trial.
The requested documents and property are to be produced at 8345 Layton Court, Frederick, Maryland 21704, at 10:00 a.m., on the fifteenth (15th) day after the date on which each party’s initial pleading or motion is required; or, if that day is a weekend or a holiday, the first day thereafter which is neither a weekend nor a holiday.
SANTA MARIA LAW CENTER
Philip J. Santa Maria, #1417
Attorney for Plaintiff
8345 Layton Court
Frederick, MD 21704
NOTE: This is designed to be served on the defendant(s) with the initial court papers.