Theresa Patterson
JUDICIARY DISTRICT OF MARYLAND
IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND
Plaintiff’s Name : Civil Trial Division
Madonna Ciccone : Compulsory Arbitration Program
Vs :
:
Defendants Name : Date…1st August, 2013
Robert Downey, Jr. Case No…2135898976
A FORMAL REQUEST FOR PRODUCTION OF DOCUMENTS BY THE DEFENDANT
According to the Maryland rule 2-422, the defendant, Mr. Robert Downey Jr., wishes to request the plaintiff, Ms. Madonna Ciccone to produce a written response and the documents requested for proper identification and it’s copying within 30 days through lawyer Philip J. Laffey, Esq. Marshal & Laffey Ltd. 50 Power Road, Pawtucket, RI 02860.
I. The written response should be able to indicate precisely that inspection will be permitted to be conducted on each of the items unless request refused, and the reason for refusal stated on the item or rather the category involved.
In accordance, documents are to be produced in the order covering on their normal course of business or be organized in the order corresponding to the requests made.
II. The requests should include all the items within your custody and control
III. The requests shall be a continuance of character, so that in the case of obtaining additional items to amend or supplement your response.
IV. In case any ambiguity in construing any the requests made or a definition or an instruction, in responding set out the matter.
DEFINITION
A. “Documents” means all and any written and/ or graphic material or matter in every type of description; a draft or reproduced, produced or original, signed or unsigned
B. “Occurrence” refers to the incident that forms the Plaintiff’s complaint.
C. “You” or “your” means the plaintiff or any individual acting or contended to act on the behalf of the plaintiff and agents or employees.
D. “Persons” refers to an individual or a corporation or a association or firm or any business entity; commercial or non-commercial.
E. “Property” refers to the residential property located at 15 Hollywood Boulevard in West Providence, Rhode Island.
REQUESTS
REQUEST NO. 1: Photographs, diagrams and any kind of sketches that relates to the allegations of the complaint made the Plaintiff. Also include additional photographs, diagrams and sketches that are expected or are to be introduced in the occurrence of a trial.
REQUEST NO. 2: All the documents that was identified by the Plaintiff in response to the interrogation done by the providers of the West Providence Tax Assessor Estelle Getty.
REQUEST NO. 3: All the reports and pieces of information that have been retained from experts in preparation for the trial or the experts that could stand as witness or testimony of the same. Include all the information regarding the recent curriculum vitae of the expert expected and other person that may be asked in the trial.
REQUEST NO. 4: Economic reports or any other reports that predicts the future expenses or losses or damage of any way and position that the Plaintiff may claim.
REQUEST NO. 5: All the documents or drafts of documents or any other prepared or working on that will be produced by any sort of expert you expect to call on the trial.
REQUEST NO. 6: All the documents and records or reports that concerns or which give evidence on the nature and the exact or purported amount of losses, damages and expenses that are made or incurred in then past , present and the future by the plaintiff or which you could make claim of.
REQUEST NO. 7: Records that show any given special damages that are to be claimed including all the invoices and receipts, statements and any other document on payment.
REQUEST NO. 8: All the diaries and journals or sort of documents that are created by the plaintiff or his behalf relating to the memorializing or the recollection on the events or any of it of the allegations made by the plaintiff or the damages and other claims thereof.
REQUEST NO. 9: Al the telephone calls records that were made by you or on your behalf, towards any other tax assessor that could form a basis on the allegations of your complaint. The records should provide the related telephone call bills, cell phone bills or rather long distance calls and any other documentation that could provide such information.
REQUEST NO. 11: Statements that have been recorded or signed by the defendants and the supposed related parties or agents or employees or any other person that relates to the occurrence of the complaint.
REQUEST NO. 12: All of the documents, statements and any sort of item that have been received by the defendant or any individual contended to be his agent or employee. Any such document or statement or item that may contend to be an admission against the defendant or the contended agent or employee or associate should be included.
REQUEST NO. 13: All the documents or statements that will support or in any war relate and refer to such position you may take or a claim on damages you may make.
REQUEST NO. 14: Any release and settlement that could lead to an agreement or actual agreement or documents that limits or potentially limits and reduces liability, both actual and potential of any of the party in the case or on any other matter.
REQUEST NO. 15: Articles and texts, abstracts and treatise or any other publications that your experts and you conform to be reliable or contend to be in relation to this case.
REQUEST NO. 16: Documents that you contend to be or verify any fact that can be relevant in making your case in relation to the allegations made.
REQUEST NO. 17: All the information or documents that have been provide to an expert witness to be reviewed and expect to call, whether they were found to be helpful on relation to the case without the possible regard on the personal opinion of the expert on the said documents or statements.
REQUEST NO. 18: Documents that relate or refer to any settlement and subrogation agreement, release or loan receipt that made between the plaintiff and any person s with regard to the claimed of square footage and damages to the property.
REQUEST NO. 19: All the copies that involve your property insurance cover. Include the tax return both federal and state in the period of the last 5 years prior the occurrence. All the tax returns in existence but not in the possession but in custody or control of the plaintiff, we request that the plaintiff to provide authorizations on the examination of the same.
REQUEST NO. 20 All the financial records, mental and any other records including bills and notes, memoranda, bills and invoices that relate to the damages to the property.
Respectively Submitted:
Philip J. Laffey, Esq. folk Towers, 1st Marshall & Laffey Ltd.23, Tiley
50 Power Road
Pawtaucker, RI 02860
Telephone no: 555-123-4567
Signature
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