A request for production of documents is a formal discovery request asking the other party to produce records, electronically stored information, and other tangible items within their possession, custody, or control. It is one of the formal discovery tools available in addition to the mandatory Rule 49 disclosure.

Requests for production are most useful when the Rule 49 disclosure was incomplete, when specific categories of documents are needed that were not included in disclosure, or when third-party records need to be obtained through subpoena rather than party disclosure.

Responses to requests for production must be made within the time allowed by the Arizona Rules of Family Law Procedure. Objections must be specific and timely. Producing documents with improper redactions or withholding documents without proper objection can have serious consequences.

Electronic discovery is increasingly common in family law cases. Text messages, emails, financial platform records, social media, and cloud-stored documents may all be subject to production. Understand what your client has before responding to production requests and advise them about preservation obligations from the beginning of the case.