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Hello, my name is ***** ***** I am a California attorney. Although you are in AZ, your question is a more general nature so I can help you with this. As I understand it, it sounds like you are supposed to help your employer's attorney with a request for production of documents from the plaintiff. The attorney will put the request in the proper format. What I would want from you as the attorney is a listing of the documentation that the Plaintiff should have that is related to the case and could lead to evidence that is admissible in court. So you could probably assemble a list of the documents as a starting point, and then the attorney can get back to your employer with more specific questions.
That is correct. I would list the documents the plaintiff would have for each job (you can also include emails and texts in the request aside from time sheets, etc.) There most likely will be overlap, but the attorney can deal with that when he/she drafts the request. It is a lot of work, but litigation is often a paperchase and discovery can make the litigation more expensive and lead to settlement.
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