Form 4.2 Combined Discovery Request

UNITED STATES DISTRICT COURTFOR A SAMPLE DISTRICT

_______________________________) Case [Form] No.:

Peter Plaintiff, ) Plaintiffs, )

)v. ) Donald Defendant, ) Defendant ) ______________________________)

Requesting Party: ________________Responding Party: _________________

COMBINED DISCOVERY REQUESTIncluding Requests for Admissions, Interrogatories and Notices For Production

PLEASE TAKE NOTICE that in accordance with the applicable court rules, the Requesting Party hereby requests that the Responding Party comply with and respond to each of the discovery requests set forth hereunder within 30 days from the date that this request is received by the Responding Party unless otherwise indicated in the request.

FOR ALL ITEMS DESIGNATED AS: “Request For Admissions,” the Responding Party is requested to admit the truth of each of the requests for purposes of this action only, and subject to all pertinent objections as to the admissibility thereof that may be interposed at trial.

FOR ALL ITEMS DESIGNATED AS: “Interrogatories,” the Responding Party is required to answer the questions separately and under oath. The requested information must be provided regardless of whether it is possessed by the Responding Party personally or by his agents, employees, representatives or persons acting on his behalf.

FOR ALL ITEMS DESIGNATED AS: “Notices For Production,” the Responding Party is to produce the requested documents at the offices of your undersigned attorney located at ___________, on the date of________, at _____ o’clock (am/pm).

Request For Admission 1:You are requested to admit that on the ______ day of _____, 20___ at approximately ___ o’clock (am/pm), you personally engaged in the following activity: ____________________.

Interrogatory 1:

If your response to Request for Admission 1 is anything other an unequivocal admission, please set forth the following information concerning the said activity specifically and in detail: (A) __________________ (B) ________________

Interrogatory 2:If your response to Request For Admission 1 is anything other an unequivocal admission, please identify all documents written or produced between __________ and _________ pertaining to the subject activity. As used herein, the term “document” shall include writings, notes, drafts, outlines, recordings and files, regardless of storage media; they include, but are not limited to, writings contained on paper, recordable tape, celluloid, disks, hard drives, electronic mail servers or any other digitally stored media. The term “document” shall also include the full range of writings described in Rule 1001 of the Federal Rules of Evidence. For each such document, please set forth the following information specifically and in detail: [a] Its title[b] Its date[c] Its author[d] The circumstances surrounding its creation[e] The media it occupies (i.e. printed, typewritten, floppy disk, etc.)[f] The person or entity who presently has possession[g] The location of the document [h] A very brief description of its contents

Notice For Production 1:Please produce all of those documents in your possession or under your control that satisfy the following conditions:[a] Its title ___________, or [and] [b] dated between _______________[c] authored by _______________[d] involving _______________[e] whose media is _______________[f] that is in the possession of _______________[g] located at _______________[h] containing _______________

[Be careful about your use of “or” and “and.” Too many of the former may result in the production of far too many irrelevant documents, while too many of the latter will produce too few. You should not use all of the parameters set forth above; use only those that are necessary. But if you must err, err on the side of “too many.”]

Date: _______________

_____________________________Signature of Attorney