§ Form 20 Motion For Production, Etc., Under Rule 34
Form 20. Motion For Production, 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 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].
Defendant C.D. has the possession, custody, or control of each of the foregoing 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 A hereto attached.
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Attorney for Plaintiff
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Address
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EXHIBIT A
STATE OF MONTANA
County of Lewis and Clark
A.B., being first duly sworn says:
(1) (Here set forth all that plaintiff knows which shows that defendant has the papers or objects in the defendant's 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.)
A.B. (Signed)
(Jurat)