FORM 20. MOTION FOR PRODUCTION OF DOCUMENTS, ETC. UNDER RULE 34

Plaintiff A.B. moves the court for an order requiring defendant C.D.

(1) To produce and to permit plaintiff to inspect, copy, test or sample each of the following documents or electronically stored information:

[Here list the documents and describe each of them.]

(2) To produce and permit plaintiff to inspect and to photograph each of the following objects:

[Here list the objects and describe each of them]

(3) To permit plaintiff to enter [here describe property to be entered ] and to inspect and to photograph [here describe the portion of the real property and the objects to be inspected and photographed ].

(4) To file a verified list of (a) any designated documents, papers, accounts, books, letters, photographs, sound recordings, images, electronically stored information, objects, or tangible things not privileged which are or have been in the defendant's possession, custody, or control, relevant to the subject matter of the pending action, whether it relates to the claim or defense of the plaintiff or to the claim or defense of any other party, and (b) the identity and location of persons having knowledge of relevant facts.

Defendant C.D. has the possession, custody, or control of each of the foregoing specified documents, electronically stored information and objects and of the above mentioned real estate. Each of them constitutes or contains evidence relevant and material to a matter involved in this action, as is more fully shown in Exhibit 1 hereto attached.

Defendant C.D. possesses information pertaining to the matters set forth in paragraph (4) above.

[Contents the same as in Form 14]

A.B., being duly sworn says:

(1) [Here set forth all plaintiff knows that shows defendant has the papers or objects in the defendant's possession or control.]

(2) [Here set forth all plaintiff knows that shows each of the above mentioned items is relevant to some issue in the action.]

[Jurat]