Obsolete Date: 3/1/2008
Plaintiff A.B. moves the court for an order requiring defendant C.D.
(1) To produce and to permit plaintiff to inspect and to copy each of the following documents:
[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, objects, or tangible things not privileged which are or have been in his 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 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.
Attorney for Plaintiff
NOTICE OF MOTION
[Contents the same as in Form 14]
|STATE OF NORTH DAKOTA,
County of _______
A.B., being duly sworn says:
(1) [Here set forth all that plaintiff knows which shows that defendant has the papers or objects in his possession or control.]
(2) [Here set forth all that plaintiff knows which shows that each of the above mentioned items is relevant to some issue in the action.]