STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
COUNTY OF ANDERSON )
) CASE NO: 2009-CP-04-00014
Robert Clarkson )
) REQUEST FOR PRODUCTION
City of Anderson Sewer Department )
and Donna Clarkson )
TO: JAMES D. JOLLY, JR., ATTY:
The Plaintiff Robert Clarkson, hereby request pursuant to Rule 34 of the South Carolina Rules of Civil Procedure and the definition of terms and instructions below, that the defendant produce and permit the plaintiff to inspect and copy the following documents:
REQUEST FOR PRODUCTION OF DOCUMENTS:
- Any and all documents indentified in response to Plaintiff's Interrogatories numbered 1 through 8.
- Any and all documents supporting the Defendants claim and defense and pertaining to this case, especially the reports and work reports on the cleaning and repair of the sewers line at the Clarkson home.
- Any and all other documents or photographs of any type, nature, or description whatsoever not produced in response to any of the preceding requests which the defendant will rely upon at trial, either for the proof of the case or impeachment purpose.
The Plaintiff requests that these documents be made available for inspection and copying at his office address below or at such place may be mutually agreed upon between the parties within thirty (30) days after service of the same upon you. In lieu of production for in section and copying at the aforesaid time and place, the defendant may, if they so desire, comply with this request by forwarding legible photo static copies of these documents to Plaintiff at his address below prior to the time mentioned above.
DEFINITION OF TERMS
- The word "document(s)" means all written, recorded or graphic matter, whether produced or reproduced or stored on papers, cards or tapes, belts, computer devices, or in the constructive possession, custody or control of you, your officers, directors, agents or employees or which are known by you to exist; and includes originals, all copies of originals, and all prior drafts, including but not limited to the following: writing, papers, correspondence, emails, drafts, notebooks, telegrams, diaries, accounts, invoices, orders, letters, reports, notes, memoranda, manuals, drawings, diagrams, sketches, charts, dictating tapes, the notes or shorthand of secretaries or stenographers or assistants, photographs, negatives, prints, tape or disc recordings, photo records, sound recordings, movie films, doctorsÕ reports, descriptions, books, checks, bank account records, memos of telephone conversations, any substance supporting or using the preparation thereof, as well as any other written material.
- The word "identify" when used with respect to a document or documents, means to describe a document or documents by date, the subject matter, name of persons who wrote, signed initialed, dictated or otherwise participated in the creation of the same, the name of the addressee or addressees, if any, and the name and addresses of the person(s) who have custody of said documents.
If any request for documents is deemed to call for the production of privileged or immune materials of whatever kind and such privilege or immunity is asserted, identify in writing each document so withheld and provide the following information:
- The reason for withholding the document;
- A statement of the basis for the claim of privilege, work product or other ground of non-disclosure;
- A brief description of the document, including the date, the number of pages, the name of its authors or preparers, the name of each person to whom it was sent, the present custodian and the subject of the document.
With respect to any responsive document which was formerly in your possession, custody or control and has been lost, destroyed or is no longer in your possession for any reason, state the type of document, the subject matter of the document, the author, the person to whom it was sent and the date on which the document was lost or destroyed.
Certificate of Service: I hereby certify that on this date I sent properly to opposing parties a copy of this pleading.
Dated: 25 Feb 09
Robert B Clarkson, pro se
515 Concord Ave.
Anderson, SC 29621