The Request for Production of Documents is usually the most time consuming and most costly of the requested discovery because of what it entails and the fact that it is ongoing. The process begins with your attorney receiving a request and then contacting you regarding the request. You will need to gather and provide to your attorney either copies or the original of the documents requested; who will then have his office review and organize those documents. Your attorney will then respond to the request and arrangements will be made for the documents to be produced. Your attorney will be working under a deadline. Usually he or she will only have 30 to 45 days from the time he receives the request to the time he must respond.
One way to keep the costs down is to organize your documents before you deliver them to 
your attorney. The request you receive will be numbered and if you set up files that correspond to those numbers and then put your documents in the corresponding files it will save your attorney’s staff valuable time and energy. Also, don’t mark out anything on the documents. If there is something that you don’t want your spouse to see let your attorney know and he or she will determine what is the best way to handle those issues. If you go through and scratch items out it will only cause questions by opposing counsel.
Opposing counsel is usually given the choice to view the documents and mark which documents he wants copied or request that all the documents be copied and delivered to him or her. One thing that your attorney will make perfectly clear is that if opposing counsel chooses to view the documents first he or she is never left alone with the documents; your attorney or his assistant will be with opposing counsel at all times during the review.
In sports it is said that the best offense is a good defense. Well, during the production of documents period the best outcome is good preparation. To prepare for the discovery process you need NOT take anything personally which is easier said than done. You must also follow your attorney’s directions completely and DO NOT hide anything from him or her. Remember, your attorney will make the ultimate decision as to which documents will be produced and which will be listed as work product or confidential.
