Three catagories of "things" in a Request for Production:
Documents (emails, text) ** The documents must be in the possession of the PARTY whom the request is made of**
Entry to Desgnated Land (to survey land, make map to explain entry) ** The land must be in the control of the PARTY whom the request is being made of**
Tangible Items (breadmaker, bat) ** must be in the custody, possession and control of the PARTY to whom the request is made **
Do not list 3 types of documents on Exam!
Used to produce, inspect and copy, test or sample, measure or survey
must be in a reasonable time and manner
must subpoena non-parties.