§ 9-11-124 - Form of motion for production of documents under Code Section 9-11-34 - Georgia Statutes

O.C.G.A. 9-11-124 (2010)
9-11-124. Form of motion for production of documents under Code Section 9-11-34

IN THE COURT OF COUNTY

STATE OF GEORGIA

A.B., )
Plaintiff )

)
v. ) Civil action

) File no.

C.D., )
Defendant )

MOTION FOR PRODUCTION OF DOCUMENTS

Plaintiff A.B. moves the court for an order requiring defendant C.D.:

1.

To produce and to permit plaintiff to inspect and to copy each of the
following documents: (Here list the documents and describe each of them).

2.

To produce and to permit plaintiff to inspect and to photograph each of the
following objects: (Here list the objects and describe each of them).

3.

To permit plaintiff to enter (here describe property to be entered) and to
inspect and to photograph (here describe the portion of the real property and
the objects to be inspected and photographed).

Defendant C.D. has the possession, custody, or control of each of the
foregoing documents and objects and of the above-mentioned real estate. Each
of them constitutes or contains evidence relevant and material to a matter
involved in this action, as is more fully shown in Exhibit A hereto attached.

Attorney for plaintiff

Address

NOTICE OF MOTION

(Contents the same as in Code Section 9-11-119)

EXHIBIT A

AFFIDAVIT

State of ,

County of

A.B., being first duly sworn says:

1.

(Here set forth all that plaintiff knows which shows that defendant has the
papers or objects in his possession or control.)

2.

(Here set forth all that plaintiff knows which shows that each of the
above-mentioned items is relevant to some issue in the action.)

Sworn to and subscribed

before me this A.B.,

day of , .

Address