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Plaintiffs Request for Production of Documents

TO: ATTORNEYS FOR DEFENDANT DEFENDANT IAM SPEEDY Mrs. Marge Abraham Mr. George Simpson 1800 East Roosevelt Rd Glen Ellyn, IL 60137 (847) 555-0001 Telephone (847) 555-0002 Facsimile

PLEASE TAKE NOTICE that in accordance with the Illinois Supreme Court Rules of Civil Procedure, Rule 214, Plaintiff Rosie Green hereby requests that within twenty-eight (28) days after service of this Request, Defendant produce and permit Plaintiff to inspect and copy all of the following documents and things at the office of Plaintiffs attorneys, Burns & Smith Law Office, P.C.

INSTRUCTIONS AND DEFINITIONS The word documents as used in this request means any correspondence, notes, memoranda, writings, reports, drafts, books, papers, drawings, ledgers, journals, charts, blueprints, photographs, e-mails, electronic data, or any other type of records or form of data compilation of any kind and any other tangible thing within the scope of discovery as defined in Rule 214. Statement means any written statement, signed or otherwise adopted or approved by the person making it or a stenographic, mechanical, electrical or other recording or transcription thereof which is a substantial verbatim recital or an oral statement by the person making it and contemporaneously recorded. You may produce a photocopy in lieu of the original of any document or thing which has been demanded above. As to any document or thing which cannot be photocopied, please identify the location and custodian of such document or thing and the times and conditions upon which it will be made available for inspection. If any document called for by any request herein is withheld because of claim of privilege or other objection, for each such document state: 1. Its date and type (e.g. letter or memorandum); 2. Its author; 3. The identity of the addressee or recipient(s); 4. The identity of all other persons who have received, copied or otherwise have been permitted to see all or part of the original or any copy thereof; 5. A description of each subject matter discussed, described or referred to therein; 6. The name of its present custodian; and 7. The specific reason for your claim of privilege or other objection. SUPPLEMENTATION Plaintiff hereby requests that Defendant supplement all responses to these Requests for Production of Documents consistent with the provisions of the Illinois Supreme Court Rules of Civil Procedure. TIME PERIOD This request for production of documents and all future requests for production of documents in this litigation, unless expressly indicated otherwise, pertain to the time period from January 2, 2011 through the date of Defendants responses. DOCUMENTS REQUESTED 1. All documents read, reviewed, consulted, examined, used, or relied upon in preparing your Responses to Plaintiffs Request for Production of Documents. 2. All policies of insurance that may furnish coverage for any claims asserted in this lawsuit.

3. All statements concerning the subject matter of this action within the meaning of Rule 214 of the Illinois Supreme Court Rules of Civil Procedure. 4. All documents that support, tend to support, prove, or tend to prove any of the allegations, facts, defenses, denials, or other matters asserted in the Answer or other response to the Complaint in this lawsuit. 5. All documents that refute, or tend to refute, any claims asserted in Plaintiffs Complaint in this lawsuit.

Dated: October 16, 2013

Burns and Smith Law Office, P.C.

Seymour Burns
Seymour Burns Burns and Smith Law Office, P.C. 3500 Ridgewood Ave Bensenville, IL 60106 ATTORNEY FOR PLAINTIFF

CERTIFICATE OF SERVICE
I do hereby certify that a copy of this REQUEST FOR PRODUCTION OF DOCUMENTS was sent by facsimile and First Class Mail, postage pre-paid, deposited in the U.S. Post Office box located at 3400 Ridgewood Ave, Bensenville, IL, to the above-referenced persons at the above-referenced facsimile number and address, on this 16th day of October 2013. Seymour Burns Burns and Smith Law Office, P.C. 3500 Ridgewood Ave Bensenville, IL 60106 Phone: (630) 555-0123 Fax: (630) 555-1234

Seymour Burns
Seymour Burns