SAMPLE ORDER FOR DOCUMENT PRODUCTION BY REDUCED DISCLOSURE
1. Each party shall give by 4pm on (date) disclosure to every other party.
2. Disclosure shall be given of those documents that:
a. are in the control of that party, and
b. are relied upon or are known to adversely affect that party’s case.
3. Disclosure shall be given by listing each document or category or class of documents.
4. The list shall identify documents in a convenient order and manner, shall assert any claims to privilege by reference to any category or class of documents, shall state what has become of any documents that a party did have but no longer has control of, state any category or class of documents not searched for and shall be signed by or on behalf of the party as complete and correct.
5. Document shall include any medium in which information of any description is recorded.