Okay, your notes are actually pretty good, just the way they are stated. There is a much more complicated production format that I can provide. However, for the limited amount of info you are requesting, the following may be sufficient for your needs:
PROPOUNDING PARTY: [Appellant(s)/Respondent(s)] [name(s]
RESPONDING PARTY: [Appellant(s)/Respondent(s)] [name(s]
SET NUMBER: [number, e.g., One]
[Demanding party] [name] demands that [responding party [name] produce the documents [and things] described below on [date] at [time] at [location], and permit the attorneys for [demanding party] to inspect, copy [and for electronically-stored data, test and/or sample] them.
[Add any definitions that will streamline the demand for inspection, e.g., The term “DOCUMENT” means a “writing” as defined by
Cal. Evidence Code Section 250.
The term AGREEMENT refers to the agreement entered into between plaintiff and defendant as alleged in the complaint.]
[Add any instructions for responding to Demand, e.g., If any documents are withheld from production on the ground of privilege, you must provide the following information as to each document in your response to this Demand:
Name of the document's author(s);
Name of the recipient(s), including the names of those receiving copies; and
Nature and basis of the privilege claimed.]
DOCUMENTS [AND ITEMS OR THINGS] TO BE PRODUCED:
1. [Identify category of documents, document, item or thing, e.g., All DOCUMENTS that comprise, reflect or refer to the AGREEMENT.]
2. [Identify next category, document, item or thing, e.g., All financial records, including ledgers, accounts, e-files and spreadsheets, reflecting or describing the sums billed and received under the AGREEMENT.]
3. [Continue listing additional items for production.]
[If requesting electronically-stored data, describe desiredmethod of production, e.g., Electronically-stored information shall beproduced in the following format[s]: [specify desired format(s), e.g.,the form or forms in which it is ordinarily maintained, [and/or]native format with metadata, [and/or]searchable.pdf format[etc].]]
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