What items can be produced under a request for production of documents?

• A. Electronically stored information
• B. Only physical boxes
• C. Only witness statements
• D. Only emails

Answer: (A)

Requests for production let a party obtain items in the other party’s possession, custody, or control, and the scope now includes electronically stored information as well as traditional paper documents. Electronically stored information covers emails, digital files, databases, and other electronic records, not just physical boxes or single types of items. That breadth is why this option is correct: it reflects the inclusion of ESI in production requests. The other choices imply limiting the scope to only one kind of item, which isn’t accurate under modern rules.