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

This template is a Request for Production of Documents and Things (RFP) issued between parties during discovery in a civil lawsuit in New Jersey Superior Court. You can customize it according to the specific facts of your case. This template includes practical guidance and drafting notes. N.J. Ct. R. 4:18-1 governs RFPs in New Jersey Superior Court. The requests can be sent to a plaintiff after the commencement of the suit or upon any other party with or after the service of the summons and complaint, with a copy to all other parties. The recipient of the request is to respond within 35 days of receipt. There are many times when you can use a template like this one for your RFPs, but always modify the document to fit the specific facts of your case. Remember that the rule requires that you state your requests with "reasonable particularity." See N.J. Ct. R. 4:18-1(b)(1). Do not serve standardized requests that will not advance your case strategy. If you are aware of a specific document or piece of evidence that you want, expressly ask for it in your RFP. Remember to state that the request is ongoing and, if the responding party comes into possession of any not-already-produced documents or things at a later time that is covered under the initial request, that it needs to be provided to requesting party. For a full listing of key content covering fundamental civil litigation tasks throughout a New Jersey state court litigation lifecycle, see Civil Litigation Fundamentals Resource Kit (NJ). For more on drafting RFPs, see Document Requests: Drafting and Serving RFPs (NJ) and Document Requests: Responding to RFPs (NJ).