Sample Discovery Request

Several readers seem to be searching for examples of discovery document requests that you can use when you are representing yourself (i.e. you are a pro se litigant).  

As an illustration for those seeking to prepare their own discovery requests, I thought I would like to post an example that I used in my own case. The file link below will connect to a PDF document that contains some pretty standard requests for documents. This is officially known as a Request for Production (or RFP).


When you examine the list of items requested you can see that document production can eat up a lot of time. This is also why it is important to keep detailed records during your divorce and why you should try to settle your case before it reaches the discovery stage.

In addition to production of documents, discovery includes interrogatories (a set of twenty questions) and depositions (sworn testimony from witnesses and both parties that can be introduced in court). Depositions are a great way for attorneys to produce billable hours.

Usually, the court will indicate when any discovery must be completed. In my case, the opposing attorney just ignored my requests for documents. The discovery commissioner who is meant to handle discovery disputes never returned my calls and the office seemed mostly empty.

A motion was then generated requesting the court to order the production of the requested documents.  The opposing attorney claimed I had not produced all of my documents and he had not realized that I was representing myself- the court, in all its wisdom, then postponed the trial another six months.  

In hindsight, I’m not sure how much hope you can pin on the discovery process. It is costly and time-consuming to enforce compliance even for information that you know exists. If the other party decides to lie about the existence of documents then it is unlikely you will ever obtain them. The penalties for non-compliance seem almost farcical. 

20 Responses to Sample Discovery Request

  1. […] to Discovery In a previous post , I provided an example of a request for production of documents in pre-trial discovery. In this […]

  2. Kent Kingsley says:

    Thanks this was extremely helpful. My lawyer has proven himself useless once again. I sent an email asking what I needed to do for discovery. 2 weekslater with no reply I called to ask. His paralegal told me I didnt need to do anything and that the attorney would handle that. Funny how he thinks he can handle it without knowledge of any details of the case. Total waste of money so far and in my opinion he has done more harm than good so hes out and i’ll just do this myself.

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    • Jason McKee says:

      Can a friend that doesnt have a law degree represent me in divorce court?

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      • QuinnFazigu says:

        To the best of my knowledge and belief, he can come with you, and give you advice as anyone would. I don’t think he could actually *represent* you unless you gave him power of attorney. Additionally, every damn state is gonna be different. In some, you don’t need a license to “practice” law.

        In any case, if you feel he has knowledge that could help you, then bring him along. He can tug at your sleeve and make suggestions whenever he likes. Play a legal Cyrano.

        Your post is dated a year ago, but with the glacial pace of these things, maybe you’re still awaiting trial.

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