Plaintiff _______ moves the court for an order requiring defendant _____

(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 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 the 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].

Plaintiff did previously, on the ____ day of ____, 19__, serve a request upon defendant for the above discovery and inspection. Defendant did on the ____ day of ____, 19__, serve upon plaintiff written response to said request, objecting to each and every of said requests, stating as reason therefor that [state reasons for objecting, as …] said requests do not relate to matters relevant and material to matters involved in this action. Defendant ________ 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.

[Signed]: ___________________,

Attorney for Plaintiff.

Address: _______________________

EXHIBIT A

STATE OF __________,

County of __________,

ss.

_______,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 the ______ day of ______, 19__.

__________________

Notary Public