Requests for production of documents - that is, asking the other side to send copies of specific papers - are an important part of discovery. Requests for production may come with the interrogatories, but both sides are free to request production of documents throughout discovery.

Requests for production should be requests for documents that are relevant to the lawsuit, the accident or your damages. This often includes copies of your health care records, receipts or invoices for your health care expenses, accident reports, witness statements and pictures of the scene of the accident. If you are claiming a loss of income, you will probably be asked to provide your tax returns for several years prior to the accident. You may even be asked to produce any notes or diaries you have kept. Either side may request any discoverable document. Your lawyer may review the request for production with you and help you copy the documents and send them to the defendant’s lawyer.

In addition to requesting documents and evidence from you, the defendant’s lawyer may also ask other people or companies for information. Most commonly, he or she may request copies of your medical records directly from your treating doctors. The defendant may also be entitled to request information about you from your employers, schools you have attended or from the military, if you have served. Additionally, if you have applied for Social Security benefits, the defendant’s lawyer may request information about your claim from the Social Security Administration. You may feel uncomfortable with these requests, but if the information is discoverable, the defendant’s lawyer is entitled to ask for these documents. In fact, you may even be required to sign forms authorizing release of the information.