SAMPLE PROCEDURAL ORDER FOR [DISCLOSURE] [DOCUMENT PRODUCTION] DISPUTES

1. If any party is dissatisfied with the [disclosure] [document production] of any other party it shall first make a reasoned request in writing to that other party that it [dicloses] [produces] and stipulate a reasonable time within which the requested documents are to be provided.

2. The reasoned request must:

a. Describe the document in sufficient detail to identify it or describe a narrow and specific category or class of documents, limited so far as possible, including by time period, author, recipient, subject matter, location and nature of document,

b. State the basis upon which it is believed the document or