How to respond to a request for production of documents
Published October 27, 2026
A request for production asks you to hand over documents. In federal court it is governed by Rule 34 of the Federal Rules of Civil Procedure; state courts have their own rules, often similar and sometimes not. A response has two parts: a written response to each request, and the documents themselves. This page goes through both in general terms, quoting the federal rule. This is general information, not legal advice. A lawyer or your court's self-help center can say what applies in your case.
Part one: the written response
Rule 34(b)(2)(B) says that for each item or category, "the response must either state that inspection and related activities will be permitted as requested or state with specificity the grounds for objecting to the request, including the reasons." It adds that the responding party "may state that it will produce copies of documents or of electronically stored information instead of permitting inspection". The committee note to the 2015 amendment calls producing copies "the common practice".
Objections have their own rule. Rule 34(b)(2)(C): "An objection must state whether any responsive materials are being withheld on the basis of that objection. An objection to part of a request must specify the part and permit inspection of the rest."
The response is signed. Rule 26(g)(1) says every discovery response must be signed by an attorney of record "or by the party personally, if unrepresented", with the signer's address, email address and telephone number.
In federal court, neither the request nor the response goes to the court at this stage. Rule 5(d)(1)(A) says requests for documents and the responses to them "must not be filed until they are used in the proceeding or the court orders filing". They are served on the other side.
The 30 days
Under Rule 34(b)(2)(A), the party "must respond in writing within 30 days after being served". If the request was delivered early, under Rule 26(d)(2), the 30 days run from the parties' first Rule 26(f) conference instead. The rule adds: "A shorter or longer time may be stipulated to under Rule 29 or be ordered by the court." Rule 6 governs how days are counted, and Rule 6(d) adds 3 days when service was made by mail, by leaving it with the court clerk, or by other means the person consented to.
State deadlines come from state rules. California's Code of Civil Procedure section 2031.260(a), for example, also gives 30 days after service of a demand for inspection (California's name for the request), with at least five days in eviction (unlawful detainer) cases.
Part two: organizing the documents
Rule 34(b)(2)(E)(i): "A party must produce documents as they are kept in the usual course of business or must organize and label them to correspond to the categories in the request". So in federal court there are two ways: hand the files over the way they are kept (a year of statements as one set, in date order), or sort them by request. For electronically stored information, if the request names no form, Rule 34(b)(2)(E)(ii) says to produce it "in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms".
State rules can be narrower. California's section 2031.280(a) says documents produced "shall be identified with the specific request number to which the documents respond."
Numbering the pages
Rule 34 does not mention Bates numbers, but a court order or an agreement between the parties can call for them. Numbering every page lets the written response point to exact pages: "Documents responsive to Request No. 3 are produced at SMITH-000001 to SMITH-000036." It also gives you a record of what went out. See Bates number format for prefixes and digits, production index for the list that ties ranges to requests, and rolling productions if the documents go out in batches.
Private numbers in the documents
Bank statements, pay stubs, tax returns and medical bills carry Social Security numbers, account numbers and dates of birth. Federal Rule 5.2(a) limits these in filings with the court: a filing may include only the last four digits of a Social Security or taxpayer-identification number, the year of birth, a minor's initials, and the last four digits of a financial-account number. That rule is about filings. In federal court a production is served on the other side, not filed, until a page is used in the case.
Whether anything can be redacted in a production itself depends on the rules, any protective order under Rule 26(c) and what the parties agree, and a lawyer or the self-help center can answer that for your case. Documents withheld or redacted as privileged have their own rule, Rule 26(b)(5)(A), which asks for a description of what was withheld. Where a number does come out, a black box drawn on top leaves the text in the file; see why black box redactions fail and redacting a bank statement.
Keeping a copy
If a question comes up months later about what was produced, the answer comes from an exact copy of what was served: the signed written response, the numbered files as sent, the index, and a note of the date and how they were sent. SHA-256 fingerprints in the index show that a file has not changed since.
A short checklist
- Note the date of service and work out the deadline.
- Read each numbered request.
- Gather the documents for each one.
- Decide, with help if needed, what to produce and what to object to.
- Write a response to each request, and sign it.
- Organize the documents as kept, or by request, as your rules allow.
- Handle private numbers as the rules and any order allow.
- Bates-number every page and make an index.
- Serve the response and the documents.
- Keep an exact copy of everything.
If you represent yourself, Bates numbering a discovery response without a lawyer goes through the numbering in more detail.
BatesNumbering.app does the numbering and the index in your browser, without uploading the files, and in the same pass looks for Social Security, account, routing and card numbers for you to review page by page. It does not decide what to produce, object to or redact; that stays with you.
Common questions
How long do I have to respond to a request for production?
In federal court, Rule 34(b)(2)(A) gives 30 days after being served, and the parties can agree, or the court can order, a shorter or longer time. Rule 6(d) adds 3 days for service by mail and some other methods. State rules set their own deadlines.
Do I file my response to a request for production with the court?
Not in federal court at this stage: Rule 5(d)(1)(A) says requests for documents and the responses must not be filed until they are used in the proceeding or the court orders filing. They are served on the other side, and state practice can differ.
Do documents have to be organized by request?
Under federal Rule 34(b)(2)(E)(i), documents are produced either as they are kept in the usual course of business or organized and labeled to match the categories in the request. California's Code of Civil Procedure section 2031.280(a) says produced documents shall be identified with the specific request number.
Can I redact Social Security numbers from documents I produce?
Federal Rule 5.2 limits Social Security and account numbers in court filings to the last four digits, but a production is not a filing. Whether redaction is allowed in a production depends on the rules, any protective order and the parties' agreement; a lawyer or your court's self-help center can answer that for your case.
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More guides: What is Bates numbering · Bates numbering without Acrobat · Bates number format and examples · Bates numbering a discovery response without a lawyer · Exhibit numbers vs Bates numbers · How to redact a PDF for free · Redacting SSNs and account numbers in court filings · Redacting a bank statement · Why black box redactions fail · Redacting a PDF on iPhone or Mac · A document production index · Rolling productions · Bates and redaction tools compared · batesstamp.com alternatives · RedactifyAI alternatives · Adobe Acrobat alternatives for Bates and redaction