Document Requests in New York: Request for the Production of Documents

by Practical Law Litigation

A Standard Document providing a sample request for the production of documents, also known as a notice for discovery and inspection (D&I) or a document demand, for a party to serve in New York state civil actions. This resource offers a model for drafting effective discovery requests that comply with the Civil Practice Law and Rules (CPLR) and the specific requirements of the supreme and county courts, including the Commercial Division Rules. It contains sample definitions and instructions to streamline the discovery process, covering key concepts like possession, custody, or control, and the format of production. This Standard Document addresses modern discovery challenges by including provisions for electronically stored information (ESI), such as data from social media, workplace collaboration tools (WCTs), and the Internet of Things (IoT). It also provides a wide range of sample specific requests that can be tailored to the specific facts of a case, helping counsel to draft requests with the reasonable particularity required by New York courts.