I am looking for a "request for production if documents" specifically regarding the Note. Any documents pertaining the endorsement and delivery of the note. Like to have something short and to the point.
This is REALLY the WORST example of a request for production I have ever seen for a pro se. (Nothing Personal John)
This kind of request is going to yield NOTHING except a protection order that bars further discovery requests. 100 requests for production that will produce THOUSANDS of pages is going to be oppressive, costly, and over-burdensome. No way around it. In my discovery I have NOT asked for more that 5 things be produced at a time (thanks Mr. Roper). It is VERY easy for the courts to rule on a motion to compel with only 5 requests and very difficult to find valid objections. After they answer I'll submit 5 more. (in reality, I'm not even requesting 5)
I would suggest that you go to the Court House and obtain some discovery request from FL. (brevard county has their documents online) They I would suggest you only lift a few questions from these requests. You can and possibly SHOULD use several smaller, well written, focused, requests.
I also think you are making tactical mistakes. It may be a good time to read a few posts on discovery here.
1. You need to have a plan and focus your discovery on answers and documents that support your position. We're not fishing. You should have a defense laid out and know what supports this defense.
2. You are looking for the Plaintiff to produce documents that HELP THEM and HURT YOU.
3. As a pro se in foreclosure you really aren't going to want them to produce a whole lot. Can you really tell me what they can produce that helps you???? I personally think foreclosure discovery should be HEAVY on Interrogatories and Admissions and only ask for the production of documents you NEED.
I agree that the request John posted was prepared by an attorney. This attorney will argue the motion to compel. You are NOT an attorney. You need to make things a little more simple so you have a more simple argument to make.
I'm not an attorney and this shouldn't be considered legal advice......Just a few thoughts to really consider.