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One common objection is that the request is to "burdensome". For example, the plaintiff is requesting 10 years of all your financial records.The production must then be completed no later than the time for inspection specified in the request or another reasonable time specified in the response. Request for Production of Documents. 1. Common mistakes and pitfalls in responses to Requests for Production of Documents. A look at RPDs, the most typical area of discovery disputes. Use this language if the request will be allowed in whole. Request for Production. Ask the other side to produce documents or things. Production of Documents; DISCOVERY; Rule 25.