IN THE ________ COURT OF ________ COUNTY STATE OF GEORGIA

A.B., ) Plaintiff ) ) v. ) Civil action ) File no. ______ C.D., ) Defendant )

MOTION FOR PRODUCTION OF DOCUMENTS

Plaintiff A.B. moves the court for an order requiring defendant C.D.:

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 to 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 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).

Defendant C.D. 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.

______________ Attorney for plaintiff

______________ Address

NOTICE OF MOTION (Contents the same as in Code Section 9-11-119) ______

EXHIBIT A AFFIDAVIT State of ________, County of ________

A.B., 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 _______ A.B., day of ______________, ____. _____________ Address