Document Requests
(Trade Secret Misappropriation and Breach of Restrictive Covenant Action) (Plaintiff Employer to Defendant)

This template is a document request (plaintiff employer to defendant) in a trade secret misappropriation and breach of restrictive covenant action. This template includes practical guidance and drafting notes. This template is intended for private employers. It is based on federal law and does not address all potential state law distinctions; thus, you should check any relevant state and local laws. Plaintiffs are encouraged to review all discovery request rules applicable to the jurisdiction in which their case is pending. For resources on employment litigation and discovery, see Employment Litigation Resource Kit, and Employment Litigation Discovery Resource Kit. For a full listing of key content covering restrictive covenant considerations, see Restrictive Covenants Resource Kit. For information on trade secret misappropriation and breach of restrictive covenant actions, see Discovery on behalf of Plaintiffs in Trade Secret Misappropriation and Breach of Restrictive Covenant Actions, Restrictive Covenant and Trade Secret Misappropriation Claims: Key Initial Considerations and Tips for Seeking TROs, Preliminary Injunctions, and Other Relief, and Defend Trade Secrets Act (DTSA) and Other Legal Claims and Recourse to Protect Employers' Confidential Information and Trade Secrets. For other templates related to trade secret misappropriation and breach of restrictive covenant actions, see Interrogatories (Trade Secret Misappropriation and Breach of Restrictive Covenant Action) (Plaintiff Employer to Defendant), and Deposition Questions (Trade Secret Misappropriation and Breach of Restrictive Covenant Action) (Plaintiff Employer to Defendant). For state-specific practice notes on trade secrets and restrictive covenants, see Non-competes and Trade Secret Protection State Practice Notes Chart.