IN THE CIRCUIT COURT OF THE 1ST JUDICIAL CIRCUIT
JACKSON COUNTY, ILLINOIS
PHIL A. BUSTER, and )
BETCHA BUSTER, ) No.: 2018 L 20
)
PLAINTIFFS, )
)
v. )
)
ROCKY ROCKEM, )
ACEY-DUCEY AD CO., )
)
DEFENDANTS. )
)
)
PLAINTIFFS’ FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
To: Rockey Rockem and Acey-Ducey Ad Co., the Defendants, and to their attorneys of
record:
Pursuant to Rule 214, Illinois Supreme Court Rules, the Plaintiffs request that you
produce the documents listed below, which are in existence and are relevant to the subject matter
of this action, for inspection and photocopying by their attorney, Jessica Rigsby, on or before
November 30th, hour of 9:00 a.m., in their office located at 123 West Main Street.
DEFINITIONS
1. “Complaint” shall refer to and mean the Complaint filed by the Plaintiffs in the above
entitled cause.
2. “Document(s)” includes, without limitation, the following items, whether printed,
recorded or reproduced by hand: forms, files, memoranda, notes, interoffice and/or
intraoffice communications, letters, telegrams, microfilms, printouts, studies, working
papers, contacts, minutes or records of conferences or meetings, reports and/or
summaries of investigations or interviews, resolutions, notices, manuals, instructions,
rules and regulations, or papers similar to the foregoing, however, denominated,
including all drafts thereof on which there appear any markings which do not appear on
the original thereof.
3. “You” shall mean and refer to the Defendants.
INSTRUCTONS
1. If any requested document is not in your custody or possession or subject to your control,
give the reason therefore and its present location and custodian of any copy or summary
thereof.
2. If, after exercising due diligence to produce the documents requested, it is not possible to
produce all such documents, explicitly so state and give the reasons therefore. Produce
any of the requested documents which you are able to produce.
3. For each document requested or portion thereof which you refuse to produce on the
grounds of privilege, state the following:
a. The authority relied upon for such a claim;
b. The nature of the privilege(s) claimed;
c. Whether the requested document(s) is (are) available in any other way, e.g.,
through some application procedure, deletion of sensitive material by authorized
individual, protective order limiting disclosure, etc.
4. For each document requested or portion thereof which you refuse to produce on the
grounds of burdensomeness, state the following:
a. The number of files and/or documents requiring review in order to comply with
the request;
b. The general titles of such files and/or documents;
c. The manner in which such files and/or documents are stored and indexed;
d. The location of such files and/or documents;
e. The estimated number of person-hours required to review such files and/or
documents; and
f. The estimated cost of reviewing such files and/or documents.
5. You are requested to furnish with your response to this request for production of
documents your affidavit stating whether the production is complete in accordance with
the request.
REQUESTED DOCUMENTS
1. Any and all photographs, movies, and/or videotapes concerning the subject matter of this
action.
2. Any and all documents containing the name and home and business addresses of all
individuals contacted as potential witnesses.
3. Each document showing all of the wages, salary, commissions or other compensation you
have received.
4. Each document you have prepared or assisted in preparing which concerns, refers or
pertains to the incident alleged in the Complaint.
5. All receipts and sales records for the work performed on Plaintiffs’ advertisements.
6. Produce a copy of the original written contract in your possession in connection with the
Plaintiffs.
7. Any and all modified amendments to the contract in connection with the Plaintiffs.
8. All documents that you intend to introduce as evidence in this case.
9. Any and all statements, correspondence, or other documents, you sent to the Plaintiffs
regarding the production of said advertisements.
10. All written reports of all expert witnesses with whom you or your attorneys' have
consulted, including, of course, those persons you expect to call as an expert witness at
trial.
11. Any and all documents identified in your responses to the form Interrogatories served
with this request.
12. All interoffice memoranda concerning the manner in which the accident occurred.
BY: Jessica Rigsby
