"Use a catch-all demand for production as your last discovery demand for production and inspection."
Your discovery requests for production and inspection always should end with a catch-all set of demands that forms a wide net, designed to keep you reasonably protected against surprise items.
About 90 days before trial (or 60 days before the close of formal discovery, send out this “catch-all demand” for production. It's a good way to eliminate surprises. A catch-all demand for production is an easy to use form (your secretary can prepare it for your signature).
Don't leave discovery without a Catch-All Demand for Production! A catch-all demand for production nets you everything that you don’t already have that the adverse counsel is likely to use at trial. It is a good trial preparation practice to use in your office.
In most jurisdictions courts do not ordinarily restrict the number of demands for production that you can make during the litigation, so the only limitation on your using a catch-all demand as your last item of discovery is that you do not make "burdensome" demands, or otherwise subject yourself to attack for adding unnecessarily to the discovery.
Our “catch-all demand” has only four categories of requests. It is designed to appear simple and straightforward (although many hours went into crafting just the right words, with no excess). This form is designed to appeal to a motions judge because it appears to be so easy for your opponent to comply with, and so sensible by not asking your opponent for anything previously produced. On its face, it shows the judge you are playing by the rules and not overreaching.
Catch-All Demand for Production gives you:
This form is so inexpensive (only $6), you will automatically gain by using the form just once. (It would take you more than $6 of your time to dictate the text of this form. Buy Catch-All Demand for Production now!
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