Kansas > Local District Court > 3rd Judicial District (Shawnee County) > Civil
Requests For Production From Defendant To Plaintiff - Kansas
| Requests For Production From Defendant To Plaintiff Form. This is a Kansas form and can be used in Civil 3rd Judicial District (Shawnee County) Local District Court . |
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Form 3.201(2)D (Requests for Production from Defendant to Plaintiff) I. GeneralREQUEST NO. 1: Copies of any and all statements of witnesses to the occurrence in question.REQUEST NO. 2: Copies of any and all statements of parties to the occurrence in question.REQUEST NO. 3: Copies of any and all reports of expert witnesses and all material received orcreated by said experts in the course of formulating any opinion relating to this case.REQUEST NO. 4: Copies of any and all medical reports pertaining to injuries sustained byplaintiff in the instant case. REQUEST NO. 5: Copies of any and all medical records of plaintiff for the ten (10) years lastpreceding. REQUEST NO. 6: Copies of plaintiffs income tax returns for the five (5) years last preceding.REQUEST NO. 7: Copies of any and all Workers Compensation records, including accidentreports, medical records, and Form 88s, in connection with any claim you have made for workerscompensation benefits. REQUEST NO. 8: Any and all photographs of the scene and/or premises of the occurrence inquestion. REQUEST NO. 9: Any and all photographs of vehicles and/or objects involved in the occurrencein question. (Objects include, but are not limited to: products, premises, striking instrumentalities,piercing instrumentalities, etc.) REQUEST NO. 10: All video tapes of any object or vehicles involved in the occurrence. (Objectsinclude, but are not limited to: products, premises, striking instrumentalities, piercinginstrumentalities, etc.). <<<<<<<<<********>>>>>>>>>>>>> 2REQUEST NO. 11: Plaintiffs entire personnel file and complete wage records from plaintiffsemployers for the ten (10) years last preceding.REQUEST NO. 12: All diagrams of the scene of the occurrence.REQUEST NO. 13: All video tapes of the scene of the occurrence.REQUEST NO. 14: All video tapes of any party showing their physical condition in any respect.REQUEST NO. 15: All repair estimates, evaluations, bills, or appraisals to any property of anyoneinvolved in the occurrence in question.REQUEST NO. 16: Provide before the occurrence and after the occurrence photos of the plaintiff.REQUEST NO. 17: Provide of any insurance claim file of any kind relating to the occurrence.REQUEST NO. 18: Provide all documents including sales tickets, invoices, warranties, ownersmanuals instructions, receipts for payment and correspondence from the manufacturer or seller,relating to the sale, maintenance and/or repair of the object or objects (including but not limited tomotor vehicles, if applicable) involved in the occurrence in question.REQUEST NO. 19: Allow physical inspection and examination of all relevant objects or portionsthereof in your possession which were involved in the occurrence in question.REQUEST NO. 20: Provide all documents designated in your answers to interrogatories.REQUEST NO. 21: Any and all personal notes, memoranda, diaries, personal journals, appointmentbooks, reports, correspondence, notes and other documents which were prepared and/or maintainedby Plaintiff which relate in any way to the claims in this lawsuit.REQUEST NO. 22: Any and all documents which plaintiff intends to use at the trial of this action.REQUEST NO. 23 A copy of your most current C.V. in the form required by DCR 3.211.REQUEST NO. 24: A copy of any reports, summaries, notes, recordings, (including audio, video,computer and other means of preservation) writings, or letters that you have obtained in this case<<<<<<<<<********>>>>>>>>>>>>> 3from or were prepared in this case by an expert or experts that may provide testimony at trial thatdirectly relates to or forms the basis of the opinions expressed by the expert or experts. The responseshall meet the requirements of DCR 3.211.Revised: 5-19-99
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