Litigation terms
Request for production
A request for production is a written discovery demand that another party produce documents, electronically stored information, or tangible things for inspection — the mechanism through which most of a case file comes into existence.
Federal Rule of Civil Procedure 34 (and its state analogues) governs: requests must describe items with “reasonable particularity,” responses are due in 30 days, and objections must be stated with specificity — boilerplate “overbroad and unduly burdensome” objections, without more, are routinely condemned. Since the 2015 amendments, a responding party must also say whether it is withholding anything on the basis of an objection.
Why it matters in practice
Drafting is a modeling exercise: you are describing documents you have never seen, based on how organizations like this one keep records. The craft is specific-but-generic phrasing — categories, custodians, and date ranges — tight enough to compel and broad enough not to miss the document you didn’t know to name.
The response side is where cases are quietly won or lost. “All responsive documents have been produced” is a representation to test, not accept: against the produced Bates ranges, against documents other productions reference, against what the deposition testimony says should exist. Follow-up requests aimed at identified gaps are among the highest-value filings in discovery.
In the fact record
Testing a production’s completeness is inventory work. FactMarshal’s coverage view keeps the expected-versus-produced comparison current as documents arrive — and drafts the follow-up request language from each gap it finds.