Free Request for Production of Documents - District Court of Delaware - Delaware

Case 1:05-cv-00015-SLR Document 21 Filed 07/27/2005 Page 1 of 7
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
STEPHANIE F. HAYGOOD )
Plaintiff, g
) C.A.N0. 05-00015-SLR
v. )
)
BARRY CONNORS, LINDA HARE-TUCKER, )
KEN KOON AND SHEILA FERRARO, )
Defendants. g
DEFENDANTS’
FIRST REQ QUEST FOR PRODUCTION OF DOCUMENTS
Defendants herewith request, pursuant to the Federal Rules of Civil Procedure, that
Plaintiff, Stephanie F. Haygood, within thirty days of service hereof, produce for inspection and
copying at the offices of the undersigned attorneys the documents described below. These
Requests are to be deemed continuing.
I. INSTRUCTIONS
l. The Instructions and Definitions set forth in Defendant’s First Set of Interrogatories to
Plaintiff are incorporated herein by this reference as though fully stated.
2. Each document you are asked to identify shall be produced in its entirety, without
abbreviation or expurgation.
3. This Request shall be deemed continuing so as to require further and supplemental
production including if, in supplemental answers to Interrogatories, you identify additional
documents.
4. If a claim of privilege or work product is made as to a document (or any portion
thereof), all portions of the document not subject to the claimed privilege shall be produced. All
documents which the Plaintiff claims privilege or statutory authority as grounds for
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