California Request for Production of Documents — Personal Injury is a legal document used in the state of California to obtain relevant information and evidence in a personal injury case. 050, effective January 1, 2024. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. Any party may obtain discovery within the scope delimited by Chapters 2 (commencing with Section 2017. Unless you provide an accounts and wish to begin using US Legal Forms, adopt these measures: Discover the kind you want and ensure it is to the proper city/area. 090. The term "communication" means the transmittal of information (in the form of facts, opinions, ideas, inquiries, or otherwise). SUMMARY OF RECOMMENDATION. gov>. Prepare the Certificate of Service. However, subsection (c) of Rule 2004 does provide that Bankruptcy Rule 901610 may be used to compel the “the production of documents” in connection with an oral examination, and thus the Rule indirectly allows for interrogatories or requests for In California, the limit for the number of requests or categories of documents within a request for production can vary depending on the type of case and certain court rules. 010), by inspecting documents, tangible things, and land or other property that are in the possession Demand for Production of Documents: A series of requests to . 2031. ca. or Interrogatory)Federal Pro Se Clinic Roybal Courthouse 255 East Temple Street, Suite 170 Los Angeles, CA 90012 (213) 385-2977 ext. ne copy for each pa. 230), you may direct a notice or subpoena at an organization: Language has been added to Rule 34(b)(1) to the effect that a request for production "may specify the form in which electronically stored information is to be produced. § 2031. using in your case. 210 – 240. 010 et seq. Feb 5, 2020 · Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031. SERVING YOUR REQUESTSMake copies. Proc. At the Law Library. LR May 8, 2020 · Request for Production Rules. 280(a). Starting from January 1, 2020, civil litigants in California are subjected to more rigorous requirements when responding to request for production of documents. Jan 24, 2020 · The California Code of Civil Procedure now requires “[a]ny documents or category of documents produced in response to a demand for inspection, copying, testing, or sampling shall be identified with the specific request number to which the documents respond. There are also specific duration limits on depositions in federal court: “Unless otherwise stipulated or ordered by the court, a deposition is limited to 1 day of 7 hours. In responding to Requests for Production of documents you have three response choices (1) agree to produce (C. Any party may, by written request to any other party: 1. No Time Limit for No Response or Unverified Responses – An unverified response is no response at all, and there is no time limit to move to compel. Superior Court (1983) 147 Cal. 60-226, and amendments thereto: A request for production (RFP) is an eDiscovery process used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. there is no limit. The rules on requests for production of documents and tangible things start at Code of Civil Procedure section 2031. 1, 2024) you may ask each party only 35 discovery questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of documents. An unlawful detainer case is a special proceeding by a landlord to regain possession of real property from a tenant. This is a major departure from the prior rule. 4th 1390, 1396. See Rule 81(c), providing that these rules govern procedures after removal. Both parties have the ability to serve requests for production of documents to the other party. 480(a). Sep 26, 2011 · Virginia is the same way, with specifically limited interrogatories, but no limit for requests for production of documents. App. (a) When an inspection, copying, testing, or sampling of documents, tangible things, places, or electronically stored information has been demanded, the party to whom the demand has been directed, and any other party or affected person, may promptly move for a protective order. ” Cal. 02. 220, 2031. (April 10, 2024) - California legislators have changed the rules of discovery in civil cases through the passage of amendments to Code of Civil Procedure sections 2016. 4:14-2(d). Oct 11, 2022 · On each page, write in the page number and the total. ) The request to produce is similar in nature to a §2031. Discovery of documents, electronically stored information, and property (a) Scope. This is a general first set request for admissions that is narrowly tailored to the specific facts of the case. 240). CCP § 12. Superior Court (2004) 122 C. Edit your sample request for production of documents california online. California Civil Discovery KFC 1020 . It may include contracts, agreements, emails, invoices, financial records, photographs, videos, or any other tangible items that may be relevant. (a) Any party may obtain discovery within the scope delimited by Chapters 2 (commencing with Section 2017. 010, subd. 030. 410(a)–(b), 2025. 01. The notice of deposition for oral examination may be accompanied by a request for production of documents and tangible things. All opposition papers must be filed and served at least 9 court days before the hearing. Look at the description to actually have California law places strict limits on the number of discovery requests a party can make. Bring a separate one for each person, business, or agency you want to subpoena. ” (Maldonado v. Eastern Dist. e of Service. The clerk will issue the subpoena. See The Florida Bar, 391 So. ”) to place additional requirements on the production of documents during discovery. The aim is to gain insight into any relevant evidence that the opposing party holds. List the evidence you will need to support the facts that prove this element. This request is typically sent by the injured party's attorney to the opposing party, such as the defendant or their insurance company, to gather documents CCP § 2031. A party demanding inspection, copying, testing, or sampling of electronically stored information may specify the form or forms in which each type of electronically stored information is to be produced. 310(c) and 2032. Discovery allows each side to build When a case with outstanding requests for production is removed to federal court, the time for response would be measured from the date of the parties’ meeting. , § 2025. 440(a). State each of the facts that will prove this element. 34(b)(2)(B) Producing Documents and ESI : Requires that the grounds for objecting to a request be stated with specificity (Requests for Production). t. Requests for production often reveal crucial information that can shape the outcome of a case. Requests for production is a discovery device by which each party can request documents and other evidence from other parties and can compel the production of evidence by using a subpoena. P. , §§ 2025. Once the documents are complete, make. 4:18-1(b)(1) (renumbered eff 9/1/10). Jan 23, 2024 · A motion to compel is a request to the court to issue an order to compel the other party to answer a question or to produce a document or object. This template was prepared by the Justice & Diversity Center, a nonprofit organization, and is not an official court form. 36 (A). Sign it in a few clicks. 290(b) (Interrogatories); CCP 2031. 270 Op. The case of Vidal Sassoon, Inc. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. 050, and 2016. At about the time the Committee was involved in its study of Rule 34, the Supreme Court of Florida promulgated some new rules governing production of documents and things without deposition. 210, and to nonparty discovery, including requests for documents in business record and deposition subpoenas Jan 11, 2013 · Requests for Production of Documents Rule 2-422. (2) The party's failure to serve a timely response was the Introduction to Discovery – Part 9: Responding to Requests for Production Part 9 of this video series from the Sacramento County Public Law Library’s Civil Self-Help Center will help you understand what Requests for Production are, and how to respond to these types of requests. interrogatories, requests for production, and requests for admission. 28 provide written responses to plaintiff's supplemental request for production of documents. > > Read More Jan 1, 2023 · The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2031. ) o People ex rel. As originally adopted, Rule 34 focused on In civil litigation, a request for production of documents is a formal method used by parties to obtain relevant information and evidence from each other. 010, et seq. For each item, write “Response to Request for Production Number” followed by the Apr 10, 2024 · San Diego, Calif. App. the m. Generally, parties are allowed to serve up to 35 requests for production of documents in unlimited civil cases, while in limited civil cases, the limit is often reduced to (a) Scope. A party may serve on any other party a request within the scope of K. The responding party has 30 days (33 days if you serve by mail) to send you a written. Take advantage of the Review button to analyze the form. California Law Revision Commission. 2d 165 (Fla. Pursuant to Virginia Supreme Court Rule 4:9, a party has 21 days to respond to unduly burdensome or seeks documents protected by the attorney-client privilege). The responding party has 30 days (33 days if you serve by Jul 1, 2005 · (c) The number of requests for admission of the genuineness of documents is not limited except as justice requires to protect the responding party from unwarranted annoyance, embarrassment, oppression, or undue burden and expense. H64 Requests for production, responses and proofs of service thereof shall not be filed unless and until there is a proceeding in which the request, response, or proof of service is at issue. It can be used in certain civil lawsuits in the Northern District Court of California. A request for production of documents at deposition in California is typically initiated by serving a written notice upon the opposing party, either prior to or during the deposition. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2033. You want to serve your demand at least 90 days before the trial to ensure there is enough time for documents to be produced and Requests for production may also be served with the summons and complaint. Sign and date. 280, 2023. > > Read More. Section 2016. 010), by a written request that any other party to the action admit the genuineness of specified documents, or 2017 Instructions: Requests for Production - General 1 of 3 Instructions: Requests for Documents . 60-234. (a) In addition to the demands for inspection, copying, testing, or sampling permitted by this chapter, a party may propound a supplemental demand to inspect, copy, test, or sample any later acquired or discovered documents, tangible things, land or other property, or electronically There are several types of document requests that can be made in California: 1. McGrath, Esq. There is no specific limit on the number. Draw your signature, type it, upload its image, or use your mobile device as a signature pad. , § 203. 090] 2030. Code § 2033. 480(b) (amended eff 1/1/13) Aug 4, 2009 · Timing: Responses to requests for production are due within thirty (30) days (five (5) days in unlawful detainer actions) if the requests were personally served, thirty-five (35) days if the requests were served by mail, and thirty (30) days plus two (2) court days if the requests were served by express mail or facsimile or electronically. For example, a request for "each and every document supporting Mar 21, 2013 · You can combine form and special Interrogatories, Requests for Admission, Production of Documents, etc as long as they do not exceed a total of 35. Below is a sample request for production of documents in a motor vehicle crash case that later settled for $750,000. California Code of Civil Procedure - Interrogatories Table of Contents Propounding Interrogatories [CCP 2030. 60-226(b), and amendments thereto: A party that responds to a discovery request by simply producing electronically stored information in a form of its choice, without identifying that form in advance of the production in the response required by Rule 34(b), runs a risk that the requesting party can show that the produced form is not reasonably usable and that it is entitled to Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. This involves asking the opposing party or other people to provide information that would not be publicly known or readily available to the party seeking it. (c). 010 ), by inspecting, copying, testing, or sampling documents, tangible things, land or and authenticity of evidence or documents. Follow the instructions on the Certificate of Service. Serve the Requests. When required in a proceeding, only that part of the request for production, response or proof of service that is in issue shall be filed. You need to set your date for production at least 30 days after service of the demand ( CCP §2031. As of January 2020, the California Code of Civil Procedure now requires that “[a]ny documents or category of documents produced in response to a demand for inspection, copying, testing, or sampling shall be identified with the specific request number to which the documents respond. 220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C. 300(c), 2031. Lockyer v. 280. Numerical Limit: In California, unless otherwise stipulated by the court, parties are generally limited to a maximum of 35 specially prepared interrogatories, 35 requests for admissions, and 35 requests for production of documents in total. Calculating the Deadline. Discovery disputes over documents usually revolve around the privilege of the particular documents, or the overall burden of producing them, not the number of requests. Depositions, interrogatories, requests for documents and requests for admission and their responses must not be filed until they are used in the proceeding or the court orders filing. G. (Code Civ. Superior Court (2002) 94 Cal. Legal Consult Recommended. g. Request for Production of Documents: This type of request seeks the production of relevant documents related to the case. 3d 681 at 685 (Pre Before you start. 60 Days After Completion of Deposition Record. Mark your calendar. California Requests for Production of Documents and Things refer to the legal process through which one party in a lawsuit requests the other party to produce specific documents or physical items that are relevant to the case. C. (O. E. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of In a limited civil case (cases demanding less than $25,000, or $35,000 if filed after Jan. 4. If your case is an unlimited civil case (more than $35,000) form interrogatories are not counted against the amount of discovery you may ask. Make a list in the template. The true scope of requests for admission is provided in Civ. If a party asserts a privilege for any document and either withholds the document or redacts the document, then the party must comply with C. 010 Demand for Production and must DOCUMENT REQUESTS. 010 - 2030. Type text, add images, blackout confidential details, add comments, highlights and more. section 2031. , Lawless, Lawless & McGrath. produce (or provide copies) of certain documents, pictures, receipts, letters, emails, reports, etc. CCP § 2033. [CCP 2030. Pro. § 9-11-34 (c)). 010) and 3 (commencing with Section 2017. Posted in Motion to Compel Further Responses. Timing is critical and different for various types of discovery and depends on if a response is served. 2030. The term "document" is defined to be synonymous in meaning and equal in scope to the There are different types of limits on requests for production of documents in California, including: 1. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. Sep 24, 2015 · The following definitions apply to all discovery requests, unless otherwise ordered by the court: (1) Communication. (§ 2025. (a) A party requesting admissions shall number each set of requests consecutively. ” The Ohio Rule 2023 California Code Code of Civil Procedure - CCP PART 4 - MISCELLANEOUS PROVISIONS TITLE 4 - CIVIL DISCOVERY ACT CHAPTER 14 - Inspection, Copying, Testing, Sampling, and Production of Documents, Electronically Stored Information, Tangible Things, Land, and Other Property ARTICLE 1 - Inspection Demand Section 2031. The time in which any act provided by law is to be done is computed by excluding the first day, and including the last, unless the last day is a holiday, and then it is also excluded. e complaint filed on January 19, 2013. If no responses at all are served, there is no time limit on when Copy the name of the Asking Party, Answering Party, and Set Number from the Request for Production. 090 creates a new set of rules for civil litigators in cases filed on or after January 1, 2024, which Mar 16, 2023 · The new law, which took effect January 1, 2020, amended California’s Code of Civil Procedure (“C. 090 and 2023. (2) Document. Timing of Motion to Compel. ) Your client may attend the deposition and refuse to comply with all or some of the document requests, placing the burden on noticing counsel to move to compel production. §2031. (b) In the first paragraph immediately below the title of the case, there shall appear the identity of the party requesting the admissions, the set number, and the identity of the responding party. J. 220 only requires 10 days notice if the notice of deposition No Time Limit for No Response or Unverified Responses – An unverified response is no response at all, and there is no time limit to move to compel. 030 (c) (2) ). copy to the Court. pp. 300(b) (Requests for Production); CCP 2033. The other side has to answer all of the requests unless they obtain a protective order. ) These potential sanctions apply to inspection demands served in written discovery pursuant to Code of Civil Procedure section 2031. This Standard Document contains integrated notes with important explanations on how to draft the caption, definitions, instructions, document requests, and signature block. 060. " Rule 34(b)(2)(B) and (C), modeled after Federal Rule 34(b)(2)(D) and (E), have been added to deal with responding to a request for production of electronically stored A sample request for production of documents (RFP) (also called an "inspection demand" or "document request") that counsel may use in a California unlimited civil action. This means the clerk signs and stamps the subpoena before you fill it out. CCP §§ 2030. State each element of your claim or defense. Committee Notes on Rules—2006 Amendment. 280 . ) May 17, 2022 · When a party responds to a Request for Production of documents the response must comply with C. Any party may serve one or more requests to any other party (1) as to items that are in the possession, custody, or control of the party upon whom the request is served, to produce and permit the party making the Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2031. 040 - Declaration For Additional Special Interrogatories, Option of Seeking Protective Order October 2006. 4th 1060, 1072-1075. 33 : Interrogatories : Reduces the presumptive limit on the number of interrogatories from 25 to 15. File Only Relevant Discovery Information Reduces the presumptive limit on the number of depositions from 10 to 5, and the presumptive duration from 7 hours to 6. A Special Interrogatory doesn't use a specific court form. Next, you can down load the California Request for Production of Documents template. See CCP §§2030. 1980). 050 through (2015) Leg Sess. Added by Stats 2004 ch 182 (AB 3081),s 23, eff. A party may serve on any other party a request within the scope of subsection (b) of K. Civ. 4000 Middlefield Road, Room D-1 Palo Alto, CA 94303-4739 650-494-1335 <commission@clrc. requires a written response and production of documents in 30 days, whereas a request to produce documents at a deposition pursuant to California Code of Civil Procedure section 2025. Use a Special Interrogatory (sometimes called a Specially Prepared Interrogatory) if you want to write the questions yourself. rtificate are serv. 210, 2031. If a lawsuit gets past its initial stages, the plaintiff and the defendant will go through a period of discovery. You use this if you want to ask questions that are specific to your case and are not included on the Form Interrogatory form. Jan 23, 2024 · The request must be specific so that your spouse can tell exactly which documents or items to produce. §§ 2031. Each document that you file must be “served” on each other party, usually by sending it in the mail. ) Similar to state practice (Code of Civ. If you are having the Request for Production served by mail, you must allow an additional 5 days, so set the date least 35 days from the date you will have the Request for Production served by mail. S. Jun 29, 2011 · If you are in the Superior Court in California there is no limit under Code of Civil Procedure section 2031. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 2025. 010), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. Even non parties can be requested to produce documents/tangible things [i] . , Lauer v. Any and all records of oral communication between RSI and UPS between March 1, 2007 and the present date that relate Revised: March 2017 Federal Pro Se Clinic“Incident” includes the circumstances and events surrounding the alleged wrongful conduct, injury, or other occurrences giving rise to this lawsuit as alleged i. In addition to complying with the provisions of Rules 26, 34 and 45, Federal Rules of Civil Procedure, a request for documents, whether a request for production or a subpoena duces tecum, should be clear, concise, and reasonably particularized. ” (Cal. ty to the case. 710), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. v. A motion to compel answers to deposition questions or the production of documents or things must be made no later than 60 days after the completion of the deposition record. , § 2031. Documents relating to the issues in the case can be requested to be produced. (a) Any party may obtain discovery within the scope delimited by Chapter 2 (commencing with Section 2017. Request for Production at Oral Examination . ” (Rule 30(d)(1). Near the end of discovery, it is wise to send out a more case-specific set to tie up any loose ends and follow-up on The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel or to quash the production Jan 1, 2012 · Civil Subpoena (Duces Tecum) for Personal Appearance and Production of Documents, Electronically Stored Information, and Things at Trial or Hearing and Declaration (SUBP-002) Orders a person who is not a party to a case to appear and testify at and bring specific documents or things to a trial or court hearing. (a) In addition to the demands for inspection, copying, testing, or sampling permitted by this chapter, a party may propound a supplemental demand to inspect, copy, test, or sample any later acquired or discovered documents, tangible things, land or other FORMULATING REQUESTS FOR DOCUMENTS. within 45 days. You can propound as many demands for production of documents as are reasonably necessary but the demands must be reasonably calculated to lead to the discovery of admissible evidence. Subdivision (a). 010. 050. 240(c)(1) and (2) and provide a privilege/redaction log. The rule previously By Emily S. Oct 18, 2023 · The Discovery Process in Lawsuits. CCP § 2025. This template provides guidance only. Ordinarily, your deadline to respond to such a request falls 33 days after the request was put in the mail Universal Citation: CA Civ Pro Code § 2031. Title t. R. 240, and 2031. 280(b) (Requests for Admission). Any party may serve on any other party a request: (1) To produce and permit the party making the request, or someone acting on his behalf, to inspect and copy any designated documents (including writings, drawings, graphs, charts, photographs, and other data compilations from which information can be obtained), or to inspect and copy, test, or sample any tangible things that are in notice when a request for documents is made the witness is “expected to make an inquiry of everyone who might be hold-ing responsive documents or everyone who knows where such documents might be held. . FRCP 5 (d) (amended eff 12/1/18). However, if you file an affidavit of necessity, showing why you should be permitted to exceed the Rule of 35, you can ask more than 35 questions, document production, admissions, etc. N. New Rules. Keep this limit in mind when writing your requests, to Aug 3, 2020 · Request for Production Rules. In the above Dec 11, 2020 · The plaintiff will then use the requests for production of documents to request copies of all policies of insurance that were identified in that interrogatory answer. 240 is effective to require any deponent who is a party to the action or an officer, director, managing agent, or employee of a party to attend and to testify, as well as to produce any document, electronically stored Feb 26, 2023 · There is no limit to the number of requests for production a party may serve; however, the court expects the number of requests to be proportional to the issues involved in the case and that a party will not use the number of requests to harass and burden another party. . documents. A. Whether on a form or not, the Request for Production will have a numbered list of documents or items they want you to produce. Apr 22, 2017 · E-Discovery UpdateThe December 2014 Case Notes discuss the following:A Tennessee federal district court decision allowing plaintiff to use predictive coding to review two million documents notwithstanding defendant’s opposition, a case management order specifying use of search terms, and initial screening with such terms; A Northern District of California order ruling that the production of The party submitting the request may move for an order under § 26. 230, 2031. 18(c)(1) with respect to any objection to or other failure to respond to the request or any part thereof, or any failure to permit inspection as requested. that you intend (or possibly intend) on . First, when responding to requests for production, the produced documents must identify the specific request to which they respond. If your case is a limited civil case ($35,000 or less) you can request up to a total of 35 combined request for admissions , form interrogatories , special interrogatories, and requests for production . 2. The revised California Code of Civil Procedure mandates that “any documents or categories of documents furnished in compliance with a request for inspection, copying, testing, or The time must be during regular business hours and at least 30 days from the date you are having your Request for Production personally served. Any and all written correspondence between RSI and United Parcel Service (UPS) between March 1, 2007 and the present date that relate directly to the April 1, 2007 contract between said parties for 2,000 GMUs. CCP § 1005 (b) (amended eff 1/1/23). tion. ext, state your Requests for Production. Oct 22, 2011 · 4 attorney answers. Ca. serve a copy of the request upon persons not parties upon all other parties to the litigation. 290(b) , 2031. This is a multi-state form covering the subject matter of the title. 280 (a) requires produced documents to be "identified with the specific request number to which the documents respond. 300(b) and 2033. Production of documents, electronically stored information, tangible things and entry onto land for inspection and other purposes. In previous years, C. 010 - General Information on Interrogatories. Unless the parties otherwise agree, or the hearing officer otherwise orders: FAILURE TO RESPOND There is no time limit on bringing the motion to compel the response to the Interrogatories, or the request for production of documents, or have the admissions be deemed admitted. (Code. The date specified for production must be at least thirty (30) days (five (5) days for unlawful detainer actions Take a blank Deposition Subpoena for Personal Appearance and Production of Documents and Things ( form SUBP-020) to your court clerk's office. 7/1/2005. 030 - Limitation on Number of Interrogatories That May Be Served. Direct the production, copying reproduction, photographing, testing or sampling of specified documents, objects or tangible things whenever relevant to the subject matter of the action. 230) or (3) object (C. When the party whose documents are sought shows that the request for production is unduly burdensome or oppressive, courts have denied discovery for lack of “good cause”, although they might just as easily have based their decision on the protective provisions of existing Rule 30(b) (new Rule 26(c)). (a) The service of a deposition notice under Section 2025. Request for Admissions: A series of statements about your case that you admit or deny. (a) In general. 010, to document requests included in a deposition notice pursuant to Code of Civil Procedure section 2025. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel or to quash the production If the deponent is a party (or an officer, director, managing agent or employee of a party), a deposition notice that includes a request for production of documents at the time of the deposition is sufficient to compel their production. 03. Dec 4, 2018 · The Georgia Civil Practice Act allows parties to a lawsuit to serve requests for production of documents on nonparties as part of the process of gathering information relevant to the subject matter of the case. ) The testimony of the chosen PMQ is then the “voice” of the deponent, in May 6, 2018 · A demand to produce documents pursuant to California Code of Civil Procedure section 2031. Requests for Production of Documents are part of "Discovery," which is very common in court cases. (d) Form of production. 020 - Timing For Serving Interrogatories. ) Where a party finds the response to a request for production inadequate and seeks to compel further responses to a request for production of documents, it must fil. According to the Rule, requests for admission can relate to “statements or opinions of fact or of the appli-cation of law to fact, including the genuineness of any documents described in the request. 280 allowed litigants to choose how they produced documents in response to a request for production. Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. Be sure the Requests and. yb hh lr xv wq dw rl ud om li