Requesting Parties: Request for the Production of Documents (RFP) (Federal)

by Practical Law Litigation

A Standard Document providing a sample request for the production of documents (RFP) for use in federal civil litigation. This Standard Document offers a framework for drafting the key components of an RFP, including the caption, introduction, definitions, instructions, specific document requests, and proof of service. It provides guidance on complying with the Federal Rules of Civil Procedure (FRCP), particularly FRCP 26 and FRCP 34, while considering the principles of cooperation and proportionality in discovery. This model includes definitions for modern forms of electronically stored information (ESI), such as text messages, data from Internet of Things (IoT) devices, and communications from workplace collaboration tools. The instructions address critical topics like the form of production for ESI, including native files and metadata, and outline procedures for handling privilege claims and objections. Counsel can use this Standard Document to draft clear, targeted, and enforceable document requests tailored to the specific facts and circumstances of their case.