SAMPLE ORDER FOR DOCUMENT PRODUCTION

1. Each party shall give by 4pm on (date) document production to every other party.

2. Documents relied upon shall be produced..

3. Documents that are produced shall be listed, 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 and shall be signed by or on behalf of the party as complete and correct