Requests for Production of Documents and Things
(RFPs) (CO)

Summary

This template request for production of documents and things (RFP) may be issued between parties during discovery in a civil lawsuit in Colorado state court. You can customize it according to the specific facts of your case. This template includes practical guidance and drafting notes. C.R.C.P. 34(a) governs RFPs in Colorado courts, and it states that a party may serve on any other party a request to inspect and copy documents, electronically stored information (ESI), and tangible things, or to permit entry onto designated land or property for the purpose of inspecting the property. A written response is required within 35 days of service of the request. C.R.C.P. 34(b). You may not seek any discovery prior to service of the Case Management Order pursuant to C.R.C.P. 16(b)(18). See Case Management Conferences (CO). You may use the below template for your RFPs, but always modify the document to fit the specific facts of your case. Remember that the rule requires you to state your requests with "reasonable particularity." See C.R.C.P. 34(b). Do not waste discovery on standardized requests that won't advance your case strategy. Rather, if you are aware of a specific document or other probative evidence, ask for it specifically in your RFP. For more on RFPs, see Document Requests: Drafting and Serving RFPs (CO) and Document Requests: Responding to RFPs (CO). For template responses to document request that may be used in Colorado, see Objections and Responses to Requests for Production of Documents (CO).