Need effective Requests for Production? This comprehensive guide offers real-world, sample RFPs tailored to civil litigation—from contracts to torts—plus expert tips to avoid objections and strengthen your case.
Drafting strategic RFPs takes more than legal knowledge—it requires case insight, procedural compliance, and the foresight to anticipate resistance. In this guide, Legal Husk provides a curated list of sample RFPs across common litigation categories, along with formatting tips and drafting strategies to maximize impact and avoid objections.
Requests for Production are governed by Rule 34 of the Federal Rules of Civil Procedure and parallel provisions in state court systems. These discovery tools allow litigants to demand:
Documents (physical or digital)
Electronically Stored Information (ESI)
Tangible items relevant to the claims or defenses
Access to property for inspection, copying, testing, or sampling
The primary function of RFPs is to obtain evidence that can:
Substantiate your client's version of events
Challenge the opposing party’s claims or defenses
Establish timelines, contractual terms, or patterns of conduct
Prepare for deposition testimony or pretrial motions
By shaping the evidentiary record early, well-drafted RFPs serve as a foundation for:
Interrogatories (by identifying who authored or received key documents)
Requests for Admission (by verifying the authenticity or content of materials)
Motions for Summary Judgment (by isolating undisputed facts)
🎯 Effective RFPs are specific, targeted, and always connected to the legal elements in your case. Broad language invites objections, while focused requests unlock the documents that matter.
Before diving into the sample RFPs by case type, it's critical to understand how to draft Requests for Production that are both enforceable and strategically sound. Poorly crafted requests lead to delays, objections, and incomplete productions—while well-crafted ones streamline discovery and strengthen your litigation posture.
Define Key Terms Clearly: Include a definitions section at the beginning of your discovery document. Define terms like "Subject Agreement," "Document," or "Defendant" to ensure clarity and avoid ambiguity in each request.
Use Date Ranges to Limit Scope: Broad requests spanning multiple years may trigger overbreadth or burden objections. Instead, tailor each RFP with a relevant timeframe based on the events at issue.
Identify Custodians or Document Types: Specify who likely holds the documents (e.g., “Produce all emails authored by John Smith regarding the merger negotiations”). This limits guesswork and increases the likelihood of a targeted response.
Avoid Ambiguous or Catch-All Language: Phrases like "all documents relating to anything concerning..." are objection bait. Instead, use focused, concrete phrasing that aligns with the claims and defenses.
Sequence RFPs with Litigation Strategy in Mind: Think about the order in which documents will be reviewed and used. For instance, begin with requests that support depositions, then follow with RFPs that support summary judgment motions or trial exhibits.
Use your pleadings as a guide. Each RFP should map back to a specific allegation in the complaint or defense in the answer. This alignment not only makes the requests more relevant but also strengthens your case when arguing against objections or in motions to compel.
RFP No. 1: Produce all versions of the agreement executed between Plaintiff and Defendant from January 1, 2022, to present.
RFP No. 2: Produce all correspondence (email, text, written) between the parties regarding the agreement terms, scope, or termination.
RFP No. 3: Produce all invoices, payment receipts, or transaction records related to performance under the agreement.
RFP No. 4: Produce Plaintiff’s complete personnel file, including onboarding documents, performance evaluations, and disciplinary records.
RFP No. 5: Produce all communications between Plaintiff and Defendant’s HR department concerning Plaintiff’s job performance, complaints, or termination.
RFP No. 6: Produce any internal investigation reports regarding the events leading up to Plaintiff’s termination.
RFP No. 7: Produce all incident reports, photographs, or surveillance footage related to the incident alleged in the Complaint.
RFP No. 8: Produce all maintenance logs or inspection records for the premises where the incident occurred.
RFP No. 9: Produce any communications with insurance carriers regarding the incident.
RFP No. 10: Produce all marketing materials, brochures, or sales communications sent to Plaintiff by Defendant between January 1, 2020, and June 30, 2022.
RFP No. 11: Produce all internal communications referencing Plaintiff or the product/service in dispute.
RFP No. 12: Produce all documents substantiating the representations made to Plaintiff.
RFP No. 13: Produce all versions of the purchase agreement, including addenda and amendments.
RFP No. 14: Produce all communications with real estate agents, brokers, or title companies regarding the property.
RFP No. 15: Produce property inspection reports and appraisals conducted during the transaction.
In tech-driven litigation, RFPs should also cover digital evidence:
RFP No. 16: Produce native-format Excel spreadsheets with metadata and embedded formulas.
RFP No. 17: Produce email communications in .msg format, including header information and attachments.
RFP No. 18: Produce logs of login history or access records for any relevant account or system.
🎯 Requesting metadata up front can prevent evidentiary gaps later.
Use bold headers (e.g., REQUEST FOR PRODUCTION NO. 1) for readability
Group RFPs by topic or claim
Maintain consistent terms across all requests
Keep each request focused on one action, one subject
📌 Example: Don’t ask for “all contracts, emails, or memos” in one RFP—break it into separate requests.
Overbroad? Narrow by timeframe, custodian, or subject.
Vague? Define key terms and use plain language.
Irrelevant? Tie the request to a specific allegation or defense.
Unduly Burdensome? Offer to discuss format, method, or phased production.
🎯 Include proportionality rationale in meet-and-confer discussions when needed.
Sample language is a starting point. Great discovery strategy is about:
Aligning RFPs with case theory
Sequencing them to expose contradictions
Using responses to prepare for depositions or motions
When you approach RFPs not just as compliance tools but as strategic levers, you build stronger cases and increase your settlement or trial advantage.
Yes—but only after tailoring them to your jurisdiction, factual context, and legal claims.
There is no fixed limit under Rule 34, but courts may limit excessive requests if they become disproportionate.
No. Reserve native file and metadata requests for cases involving digital audits, financial records, or fraud claims.
Send a deficiency letter, request a meet-and-confer, and if unresolved, file a motion to compel under Rule 37.
Not the requests themselves—but the documents you obtain through RFPs often form the foundation of trial exhibits.
At Legal Husk, we help law firms and legal departments transform their discovery process with:
Custom RFP sets aligned with pleadings
Strategic sequencing and custodial targeting
Objection-resistant formatting
Support with privilege logs, tracking, and metadata
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