Interrogatories and request for production of documents. ru/a5op/january-job-vacancies-2024.

) Interrogatories and requests for admission are additional tools that parties can use to discover information before trial. You should respond candidly to requests for admissions, since you will be answering under oath. Cioffi Remmer. RESPONSE: 12. 12953 US-301 #102e. “Plaintiff” shall mean [Consumer]. Discovery requests involve serving the Interrogatories and the Request for Production of. Discovery-Related Interrogatories and Document Requests: These interrogatories and document requests aim to uncover relevant facts, evidence, witnesses, or documents that either party intends to use during the trial. Jurisdictions often have their own rules regarding the number of interrogatories. 3d 681 at 685 (Pre Apr 19, 2024 · See Part III: Interrogatories and Requests for Production of Documents. Step one: Read the local rules. The side receiving the request has 30 days to send these documents directly to A motion to compel responses to interrogatories or requests for production is made through a motion. Interrogatories are written questions that are answered in writing under oath. It’s equally likely that your spouse’s lawyer will send some Interrogatories Interrogatories are written questions that are sent by one party to another. (F) The commission may order the production of documents on its own motion. You absolutely cannot assume that every jurisdiction follows the FRCP as a model (25 interrogatories). written questions. likely serve the discovery requests to you, the Complainant (EEOC) or the Appellant (MSPB). Nature and scope. A motion is a request to the judge to issue an order of some sort. Interrogatories to parties. Our also attorneys provide more information on dog bite lawsuits and discovery below that can help you with deposition questions, interrogatories, and requests for production of documents. If you or a member of your family has been injured in a dog attack, please give us a call at (916) 921-6400 or (800) 404-5400 for free, friendly advice. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents. To view locked content, sign in . Our last module will cover requests for document production and physical and mental examinations. 2) The following Requests for Production of Documents are adopted by the Court: a) Plaintiff’s Request for Production of Documents, Exhibit “E” and b) Defendant’s Request for Production of Documents, Exhibit “F. Interrogatories. " — Massachusetts Practice v. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. 5: All your written document or sample retention policies in A Request for Production of Documents is a request to a party to hand over certain defined documents. G. Federal Rule of Civil Procedure 33 covers interrogatories, and FRCP 36 covers requests for admission. Unlike interrogatories, there are no hard limits on the number of requests that can be sent, but if it’s too onerous, a judge might step in to limit any abuses. A party is not limited to only 30 requests for production of documents. (a) Availability; procedures for use. ) Trial documents (transcripts, jury instructions, you name it) Electronic Discovery. If the motion is based on a failure to respond to a request, proof of service of the request must be filed with the motion. Current as of March 28, 2024 | Updated by FindLaw Staff. 10:1. Interrogatories are written questions posed to the opposing party, for which a response is required, under conditions specified by the jurisdiction ’s rules of court procedure. Requested items are being served with the response. Plaintiff objects to each Request: (1) insofar as it calls for the production of. Requests for production require the other side to produce documents regarding the case. 220 [“. So long as that motion is heard within 30 days of filing, it too can stave off the (2) when used with respect to a document, means to state (a) the type of document (e. Plaintiff(s) Request for Production of Documents Directed to Defendant(s) the person to whom these interrogatories are addressed. Like the other discovery requests, it’s important to 804. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. Requests for production (document requests) Requests for production are asking that the person produce the specified documents for you. You have been served with the original of Interrogatories and Requests for Production under I. For additional information about interrogatories as well as instructions, forms, and example documents: How to use written questions and requests for documents in a family You are required to respond to this request no later than thirty (30) calendar days after receipt of this Request for the Production of Documents. The plaintiff also submits a Request for Admissions, Production of Documents and Things, and the form also contains a Certificate of Service. : 24-C-17-001028 OT. Requests for interrogatories are detailed questions relevant to a marriage that a party must answer to the best of their ability. (a) Discovery methods. 3) The foregoing answers to the interrogatories and responses to requests for production of documents are true, correct and complete. Create your caption. Remember, the Plaintiff must prove 2 things to win a debt collection lawsuit: You owe the debt, and. There are 4 common ways to do Discovery. This is a general first set request for admissions that is narrowly tailored to the specific facts of the case. Document requests are requests that you provide copies of documents. Discovery samples, including depositions, interrogatories, requests for production of documents, etc. 2. These help establish the defendant's liability and the potential damages claimed by the plaintiff. Requests for the production of documents are a written tool used in the initial written discovery phase of most personal injury lawsuits. (“Santander”), including any other name by which it is or was known, and all agents, employees, or persons who act or (c) Request for production, entry or inspection. Production of Documents and Things. 3) Depositions. , CCP § 2031. Having tangible proof of this information helps your attorney prepare effective Oct 6, 2016 · Local Rules. this request. 1A-1, Rule 33. Step two: Go back and read the local rules again. 1 Request for Production and Inspection to Parties. Rules 26, 33, and 34. (415) 944-2456. § 9-11-37(b)(2) without conducting a hearing on willfulness because the sellers did not file answers to a broker's request for interrogatories and production of documents within the time period prescribed by O. 2 “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and Requests for production are document requests — one side requests the other side to produce documents relevant to the case. For example, a request for "each and every document supporting Dec 28, 2019 · 1) interrogatories; 2) requests for production of documents and inspection; 3) requests for admissions; 4) depositions; 5) subpoenas duces tecum; 6) physical and mental examinations. The amount of the debt they claim you owe is correct. (813) 639-8111. PLAINTIFF’S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Definitions and Instructions 1. basis for the objection. Note: This is a sample of the Plaintiff’s medical malpractice lawyers request for production of documents in a medical malpractice case. (3) The party submitting the request may move for an order under MCR 2. A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing. In 2022, more than 99% of information now being created is housed electronically. The scope of this section is basically determined by the extent of discovery which can be made by the party with the intervention of the court. For example: “produce your tax returns and W2s for the last five years. Sep 6, 2022 · INTERROGATORIES AND REQUESTS FOR PRODUCTION TO: DEFENDANT IDAHO WATER RESOURCE BOARD AND TO: COUNSEL FOR DEFENDANT I. 310(c) and 2032. Mar 27, 2014 · Website. Some of the interrogatories will mirror the requests for documents; a party Apr 16, 2019 · A Request for Production of Documents (often referred to as a Notice to Produce) requires a spouse to provide the other spouse with certain documents for review. The interrogatories must be answered, in writing, within 30 days; the requested documents must be produced within 30 days. The primary rule governing requests for production is CR 34. The party answering the interrogatories must do so under oath. The relevant code sections demonstrating a party’s obligations in responding to these discovery devices are below with emphasis added: INTERROGATORIES Feb 28, 2018 · The key to ensuring that your requests garner the right documents is to make sure that the requests are as clear and concise as possible. Sample Discovery: depositions, requests for admission and other discovery in personal injury cases. Louisiana Plaintiff's First Set of Interrogatories and Request for Production of Documents is a crucial legal document used during the discovery phase of a civil lawsuit in Louisiana. ANSWER: 11. The commission staff and any party in a formal proceeding before the commission, other than a proceeding under 5VAC5-20-100 A, may serve written interrogatories or requests for production of documents upon a party, to be answered by the party served, or if the party served is an entity, by an officer or agent of A party that responds to a discovery request by simply producing electronically stored information in a form of its choice, without identifying that form in advance of the production in the response required by Rule 34(b), runs a risk that the requesting party can show that the produced form is not reasonably usable and that it is entitled to Interrogatories Interrogatories are written questions that are sent by one party to another. (Pressley v. Nov 24, 2020 · On December 4, 2019, Plaintiff served his First Set of Interrogatories, Request for Production of Documents and Requests for Admissions on Defendant. Please provide a complete copy of the Complainant’s file and any other Requests for Documents. 1 See, e. Although these requests are most commonly used to obtain copies of documents, they can also be used to test, measure, photograph, etc. Rule 33. May 2, 2024 · With regard to interrogatories which request information and data obtainable from available documents, the general rule is that a party should not be permitted to compel his opponent to make compilations or perform research and investigations with respect to statistical information which he might make for himself by obtaining the production of Dec 11, 2020 · Conclusion. A. 9-11-34: Requests for Production of Documents. To the extent any request for production is objected to, please set forth a complete. 316, 317. ”]. Boehlke (1963) 33 F. § 28:17. 4) Request to Admit. Requests for production often reveal crucial information that can shape the outcome of a case. Jan 22, 2022 · 3. A party may serve on another party–no later than 30 days before the end of the discovery period–a request for production or for inspection, to inspect, sample, test, photograph, and copy documents or tangible things within the scope of discovery. Requests for production may be used to inspect and copy documents or tangible items held by another party. Good luck with your case! Sample dog bite complaint; Questions and answers about Maryland dog bite cases Mar 17, 2022 · Requests for production of documents ask a party to provide documentation for any account, property, asset or debt relevant to a marriage. Interrogatories are questions that require a written response. Riverview Florida, 33578. Below is a sample set of interrogatories and requests for The Interrogatories and Request for Production of Documents - Louisiana is a document needed to be submitted to the relevant address to provide some information. Be sure to look for: Number of interrogatories. Procedures. Free Consultation (800) 553-8082 Miller & Zois helps FORMULATING REQUESTS FOR DOCUMENTS. Notes of Advisory Committee on Rules—1946 Amendment INTERROGATORIES; REQUESTS FOR PRODUCTION OF DOCUMENTS To: Pressler & Pressler, Esqs. kinda speaks for itself. In divorce, the normal focus of discovery Oct 20, 2020 · First, the substantive portions of Defendant's Answers to Interrogatories and Request for Production of Documents (as opposed to the attorney-drafted objections) were not verified until approximately September 3, 2019 and therefore were not technically answered until that date. gathering of evidence. You may also include the Request for Admission. ANSWER: 12. CCP §§ 2030. (Doc. This request for production may be complied with by mailing copies of the requested documents to Defendant within thirty (30) days of the receipt of. provide parties with a method by which admissions of facts may be obtained and used in support of, or in opposition to, summary judgment motions or at trial. This content is locked. However, unlike the 25-question limitation on interrogatories, there is generally not a limit on the number of requests for production of documents you can serve. No, they are not the same thing. Requests for admissions are a helpful discovery device that in most jurisdictions can be propounded until the time of trial. REQUEST NO. Advisory Commission Comment [2020]. . May 8, 2020 · Requests, motions, and documents pertaining to discovery include Initial Disclosures, Rule 26(f) Report, Request for Production, Response to Request for Production, Interrogatories, Responses to Interrogatories, Requests for Admission, Responses to Request for Admission, Notice of Deposition, Subpoena, and Response to Subpoena. URCP 6(c). (a) Scope. 015, any party may serve upon any other party written interrogatories to be answered by the party served, or, if the party served is a public or private corporation or a limited liability company or a partnership or an association or a governmental agency or a state officer in an action arising out of the officer's performance of employment, by any Requests for admissions "Written requests for admission . For more information on requests for production of documents see URCP 34. com. R. A written motion consists of four parts (the Notice of Motion and Motion are combined): Notice of Motion and Motion; Points and Authorities; and. A request for production, as the name suggests, is a request for another party to produce something, usually copies of documents. Sep 10, 2021 · (E) Where a request calls for the production of a document previously furnished to the party submitting the request, it is a sufficient response to specify the circumstances under which the document was previously furnished to the party submitting the request. But when serving a second set of any of these discovery tools, that practice is not used. You can use the following key defined terms and phrases: • “DOCUMENT” and “DOCUMENTS” shall mean and include (1) any “Writing,” “Original,” and “Duplicate” as Interestingly, AB 1349 also added a procedure for transmission of electronic versions of the responses to interrogatories and requests for admission: “Upon request by the propounding party after receipt of the responses to the [interrogatories/requests for admission], the responding party shall provide the responses in an electronic format to Sep 9, 2014 · Instead the Discovery Act requires the party to respond in writing to each interrogatory, request for production of document and request for admission whether it is a response or an objection. Oct 18, 2023 · Requests for admissions are ways to narrow the dispute by identifying points on which the parties agree. 26. Any party, without leave of the Judge, may serve on another party a written request to produce and permit inspection, copying or photocopying of designated documents or objects, or to permit a party or his agent to enter upon designated property to inspect and gather information. 08(1)(a) (a) Except as provided in s. Requests for production are the means by which you can ask the other party to make copies of documents, photographs, records, etc. _____ _____ Endnote. The aim is to gain insight into any relevant evidence that the opposing party holds. This can make the litigation more efficient by limiting the evidence presented at trial to genuinely disputed matters. The Court will not entertain objections to the standard interrogatories or document requests. Your response(s) and the documents are to be sent to the undersigned at 104 Church Lane Suite 201, Baltimore, Maryland 21208. And even then, the dilatory party may file a motion to extend his time to answer. mail they have 7 extra days to respond. Interrogatories or requests for production of documents and things. For details on how interrogatories will work in your case, and what to expect requested herein, pursuant to Rule 196. Please visit our site to learn more and request a free trial today. Mar 8, 2023 · The party must respond to the discovery request with one of the following prompts: Permitted as requested. ”. DEFINITIONS AND INSTRUCTIONS . v. In addition to complying with the provisions of Rules 26, 34 and 45, Federal Rules of Civil Procedure, a request for documents, whether a request for production or a subpoena duces tecum, should be clear, concise, and reasonably particularized. Real Estate Attorneys. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property for Below are sample interrogatories in a dog bite lawsuit. Deposition. Message View Profile. Frequently, the documents requested contain information that supplements what was discovered during interrogatories. will be included in the production. If you are involved in a divorce, it is likely that your attorney will send out interrogatories and requests for production of documents on your behalf. REQUEST FOR PRODUCTION NO. Jun 8, 2021 · Part four will focus on the next steps of the discovery process: interrogatories and requests for the production of documents. Drafting RFA’s, interrogatories and requests for production of documents with their use at trial in mind. Discovery is a term for the formal procedures used by parties to a lawsuit to obtain information and establish facts Civil Practice § 9-11-26. Requests For Production. Now comes the Plaintiff, Mary Elizabeth Hayman, by and through her attorneys, Plaintiff Mary Hayman (“Plaintiff”), by and through his attorneys, Miller & Zois, LLC Nov 13, 2023 · This provision allowed a party to use interrogatories for purposes of document production, despite the fact that Rule 34 specifically governs that discovery device. FROM: MARY HAYMAN, Plaintiff. P. Below are sample interrogatory questions propounded in a typical car accident lawsuit. Typically, if you requested a document, but the other side claims it doesn't exist, you can object to the judge if they try to introduce the document at trial. The case of Vidal Sassoon, Inc. A request for production is subject to many of the same time limits and objection rules discussed above. Request for Production of Documents and Things. Posted on Mar 27, 2014. More Sample Interrogatories. Identify and describe all books, documents, photographs or other tangible things which the defendant will rely on in defense of the claims in the complaint and as to each, state: In a Use of Force Case, identify and produce all documents concerning any employment-related proceeding, whether administrative, civil or criminal, in which any defendant was formally counseled, disciplined, punished, criminally prosecuted or otherwise made the subject of remedial action in connection with having used force on an inmate. Mar 2, 2006 · 11. Rule 33 (a) thus gives a party, in the case of original interrogatories, 75 days, and in the case of further answers, 60 days, to file answers before the guillotine can fall. 10. Near the end of discovery, it is wise to send out a more case-specific set to tie up any loose ends and follow-up on Discovery can help you get documents and evidence to support your case before you go to court. ) At a status conference on December 30, 2019, the Court ordered Defendant to respond to these requests by January 10, 2020. g. 12: Any DOCUMENT prepared during the regular course of business as a result of the incident complained of in the PLAINTIFF’S Complaint Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. Interrogatories are written questions sent by one party to the other party for the latter to answer in writing under oath. and to request the inspection of property. An experienced personal injury attorney will know how to use dog bite discovery tools like requests for production of documents to collect and assemble that evidence. S. This rule restates the substance of [former] Equity Rule 58 (Discovery—Interrogatories—Inspection and Production of Documents—Admission of Execution or Genuineness), with modifications to conform to these rules. Mar 14, 2022 · and used or relied on in preparing your answers to the Interrogatories. Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit. “Defendant” shall mean Santander Consumer USA, Inc. Personal injury attorneys have to do a good job from the beginning of the May 15, 2024 · Much of the discovery process is conducted on paper, including through interrogatories and requests for production of documents. Under Rule 34, the requesting party may "inspect and copy" documents and must bear the expense of making copies. Instead, 90% of lawyers (maybe more) number the first interrogatory in the second Answer. 31 at 1-2. A. Sample Car Accident Interrogatories. C. Below is a sample request for production of documents in a motor vehicle crash case that later settled for $750,000. Request for production—Will contest. Please complete the answers within the space Requests for Production of Documents. : CASE NO. Northeast New Jersey Legal Services May By means of demands for production of documents, written questions submitted (interrogatories and Requests for Admissions) and depositions (oral examination under oath before a reporter) the typical litigator in the United States will spend a hundred hours conducting discovery for every hour spent in the court room. Documents in this context may include invoices, reports, emails, text messages, and other types of documentary evidence. 804. Easily search more than 600,000 legal forms to find the exact form you need. This form is available on Westlaw. the production of documents that were prepared for or in anticipation of litigation, constitute attorney work product, contain attorney-client communications, or are Sep 16, 2020 · 196. Indeed, the Federal Rules now permit a plaintiff to serve discovery requests 21 days after service of the complaint. Each question should seek specific information pertaining to your lawsuit. Please take notice that Defendent [Defendant 2] demands answers from plaintiff to the following Interrogatories, and requests the production of the following documents in the time and manner specified in the Court Rules. The types of documents that may be requested at this stage are voluminous. But it’s only one aspect of a larger legal concept known as “ divorce discovery ,” which is basically an information-gathering process. Superior Court (1983) 147 Cal. These requirements are discussed in Superior Court Civil Rules CR 33 and CR 34. 01 is amended to require that objections to interrogatories be stated with specificity. 2015 October. Agency will most. The party from whom discovery is sought is not required to make Aug 1, 2015 · In the practice of law, interrogatories are the most commonly method used in discovery, or in the effort to obtain information from an opposing party to a lawsuit. Responses and objections to requests for production, inspection, and/or copying of documents, electronically stored information, or tangible things are due within 30 days of service of the requests and shall state when and how the responding party will make responsive material available. State and identify the name and address of every person the defendant intends to call as a witness at trial. ” 3) Objections. A judge once wrote in an opinion, “Ask me a foolish question and I’ll give you a foolish answer. The term "document" has the broadest meaning accorded to it by Rule 34 of the Jun 20, 2024 · 1) Interrogatories. The amendment is intended to make clear that vague, generalized, or “boilerplate” objections are improper. Any party may serve on any other party a request: (1) To produce and permit the party making the request, or someone acting on his behalf, to inspect The commission staff and any party in a formal proceeding before the commission, other than a proceeding under 5VAC5-20-100 A, may serve written interrogatories or requests for production of documents upon a party, to be answered by the party served, or if the party served is an entity, by an officer or agent of the entity, who shall furnish to the staff or requesting party information as is the person to whom these interrogatories are addressed. Instead, objections should be specific as to the grounds for the objection, describing the reason (s - Trial court did not err in entering a default judgment against sellers pursuant to O. Jun 3, 2020 · Riverview Florida, 33578. 3. letter, memorandum, handwritten note, facsimile, e- -mail) (b) its date of origin or creation; (c) its author and addressee; (d) its last known custodian or locations; and (e) a brief description of its subject matter and size. Riverview. See a blank sample of an Interrogatories and a Request for Production of Drafting discovery documents for effective use at trial. You can use more than one. www. D. Part VII offers additional Model Discovery. Respectfully submitted, Miller & Zois, LLC 1 South St, #2450 Baltimore, MD 21202 (410)779-4600 (410)760-8922 (facsimile) Attorney for the Plaintiff. G. App. [6] [7] This caption should look exactly the same as the caption on every other document. Request for Production of Documents in an auto accident case. _____ _____ Construction LLC serves the following requests for production of documents on Defendants Base 360, LLC and Nicholas Gilley to be answered separately and fully, in writing and under oath, within thirty (30) days. Interrogatories are sets of written questions one party sends to the other. Before you start. Parties typically issue request for documents for all relevant documents pertaining to the facts and damages of a case. 5VAC5-20-260. 313(A) with respect to an objection to or a failure to respond to the request or a part of it, or failure to permit inspection as requested. It has to be completed and signed, which can be done in hard copy, or using a certain solution such as PDFfiller. Oct 12, 2016 · The key to advancing an automobile accident case is a streamlined set of requests to send to the at-fault party, as shown below: O. Requests for the Production of Documents. This article will review Interrogatories, Requests for Productions, and Admissions of discovery that parties propound upon another party in writing. Documents to the Agency. Copies of all stock certificates in which you and/or your spouse have or had an Chapter 28. , any type of physical evidence in the other party’s possession or control. . ) To simplify the document demands, interrogatories, and requests for admissions, it is helpful to include defined terms or phrases. PROCEDURES A. 2) Request for Production of Documents and Things. 49A (Discovery), s. Any DOCUMENTS identified in any other parties ’ Answers to Interrogatories. Copies of all documents which constitute those identified or referred to in the United States’ Interrogatories addressed to you and served simultaneously with this Request for Production of Documents or in the response to those Interrogatories. 4: All Documents supporting or tending to support the allegations of the Complaint. 3: All Documents you believe refute or tend to refute the allegations of the Complaint. Serve document requests early in the case—you will need the evidence to depose witnesses, to prepare your witness to be deposed, and to determine what additional discovery to request. Generally, a party has 28 days to respond to a request for production of documents, but if the requests were served by U. documents not in Plaintiff’s possession, custody, or control; (2) insofar as it calls for. I know the contents thereof. No items have been identified-- after a diligent search-- that As part of the discovery process, the parties send written questions (“interrogatories”) to each other and request the production of relevant documents. - Any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or governmental agency, by any officer or agent, who shall Interrogatories and requests for admission are additional tools that parties can use to discover information before trial. Apr 7, 2023 · The custom in Tennessee is that interrogatories, requests for production of documents, and requests to admit are sequentially numbered. 300(c), 2031. Click on the links below to download the content: Report of KCBA Pattern Interrogatory Subcommittee (PDF) General Order RE: Prospective Application of Discovery Limits (PDF) Pattern Interrogatories and Requests for Production of Documents (Family Law) (PDF) Pattern Interrogatories and Requests for Production of Documents (Family Law) (DOC The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. Interrogatories A request for production (RFP) is an eDiscovery process used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. Requests for the Production of Documents are a Defendant's Interrogatories Addressed to Plaintiff(s) - Motor Vehicle Liability Cases Plaintiff Interrogatories to Defendants - Premises Liability Cases Defendant's Interrogatories Addressed to Plaintiff(s) - Premises Liability Cases. 11: Any DOCUMENTS received pursuant to a subpoena request in this case. That is as it should be. (a) Request. 727realestatelaw. Below are plaintiffs’ request for production of documents propounded to a dog owner in a dog bite case. The top of the first page of your interrogatories must include the same caption that appears at the top of the first page of every document that has been filed with the court in your case. A common task in a young litigator's career is drafting written discovery requests. 2) I have read the foregoing answers to the interrogatories. Production will take place at a specified time and place, if you are objecting to the original time and place of production. §§ 9-11-33(a)(2) and9-11-34(b)(2 Jul 7, 2022 · The primary rule governing interrogatories is CR 33. (d) Requests for admission —(1) Content. In most cases, these would be documents that you have under your control or can easily obtain, such as medical bills, pay stubs, proof of lost wages, etc. fc fy xc sy dd uq oo rv lq li