Demanding Party: __________ [demanding plaintiff or defendant]
__________ [name]
Inspection Demand Set _____ [set number]
Responding Party: __________ [responding party plaintiff or
defendant] __________ [defendant name]
To __________ [responding party], __________ [responding party
name], and _____ [responding his or her or its] attorney:
__________ [Demanding party], __________ [demanding party
name], demand that __________ [responding party] produce for
inspection and copying the following documents or categories
of document in _____ [responding his or her or its]
possession, custody, or control. The documents or categories
of documents must be produced on __________ [date at least 30
days after service of demand], at __________ [docunents
produced time], at __________ [reasonable location, such as:
the office of __________ (name), __________ (plaintiff's or
defendant's) attorney], located at __________ [demanding party
attorney address], __________ [demanding party attorney city],
__________ [demanding party county]County, California.
Pursuant to section 2031(h) of the Code of Civil Procedure,
__________ [responding party] is required to serve a written
response to this inspection demand with _____ [20 or as the
case may be] days from the date of service of this demand.
1. __________ [List and number each document or category
of documents separately, describing each in enough detail to
allow responding party to easily identify items demanded, for
instance:
a. Every written statement or transcription of a
recorded statement, and all notes of conversation made by
any witness to the accident that is the subject of this
suit.
b. Every report, photograph, recording, or other
writing prepared by investigator __________ (invesigator
name), based on _____ (investigator his or her)
investigation of __________ (accident scene) located at
__________ (address), __________ (accident scene city),
__________ (accident scene county)County, California.
c. Every photograph that shows any personal
injuries sustained by __________ (responding party) in
the accident that is the subject of this suit.
d. Every bill, statement, report, record, or other
writing that pertains to personal injuries sustained by
__________ (responding party) in the accident that is the
subject of this suit.]
2. __________ [Specify manner in which activities other
than inspection will be performed, for example: The items
produced by __________ (responding party) will be subjected to
inspection, photographing, testing, and sampling as follows:
a. Photographic enlargement of each document
produced.
b. Handwriting analysis of each handwritten
document.]
