What is a Request for Production of Documents? 
You can use a Request for Production of Documents to inspect and copy relevant documents in your spouse's possession. A Request for Production of Documents can only be used between the parties involved in the case. It cannot be used to discover information held by a third party (for information about obtaining information from third parties for your case, see the Subpoenas page of this guide).
What are "Documents"?
Documents include ESI (Electronically Stored Information). Such "documents" include email, pictures, computer files, etc. If you are requesting ESI to be produced, you should specify the form in which you prefer the ESI to be produced. See CCP sections 2020.410, 2020.510, 2025.220, 2016.020 for more information on electronic records.
How many Document Requests?
There is no limit to demands for production of documents (CCP2031.010(a)). However, you must be reasonable. You cannot request so many as to be unduly burdensome and expensive, annoying, embarrassing, or oppressive. Remember, what you serve on the other party, you may receive the same requests from the other side.
Drafting the Request
A Request for Production of Documents needs to be written on pleading paper because there is no court approved form. In your request, you need to state a date, time, and place where the documents are to be provided for you to inspect and copy. You should prepare a separate list of the items you want produced. Use a separate paragraph for each type of document. Number each paragraph. For instance, request federal tax returns in one paragraph, pension or retirement plans in another, and monthly bank statements in another. Ask for records back to the time when you think your spouse started thinking about divorce. However, be reasonable. The request must be specific so that your spouse can tell exactly which documents or items to produce.
You need to set your date for production at least 30 days after service of the demand (CCP §2031.030(c)(2)). You want to serve your demand at least 90 days before the trial to ensure there is enough time for documents to be produced and examined, and for any further motions to be made. The place for production of documents should be an office, or some other location with an available photocopy machine (CCP §2031.030(c)(2)-(3)).
Your spouse only has to produce items or documents of which he or she has custody or control. However, if he or she can get a copy easily, and you have no access, then he or she must get the copy for you. If your spouse gives the documents to his or her attorney, that does not make them subject to the attorney-client privilege.
The pleading must follow the pleading format indicated in the California Rules of Court, Rule 2.100. A sample pleading paper format for use in drafting the Request for Production of Documents can be downloaded at https://sandiegolawlibrary.org/pleading-paper-template/. Click on "Pleading Paper Template - Download."
Example of Request for Production of Documents
The following document is a modifiable template that contains the sample language of the Request for Production of Documents.
This sample is based on the book How to Manage a Contested Divorce in California, which is no longer being published and the CEB Family Law Financial Discovery, a resource that is available in print or in the Onlaw database at the law library. This sample is specific to questions focusing on expenses and only for use if that is the issue. If this is not an issue in your case, do not use these questions. Remember the questions must be relevant to your specific situation. The template is modifiable and can be edited to fit your needs. We recommend you do more research in our Library resources to select the best questions for your situation.
How to Respond: Request for Production of Documents 
Review California Code of Civil Procedure §2031.210 - §2031.320 for detailed information about how you must respond to a Request for Production.
Each item of the request must be responded to separately, and there are only three acceptable responses: 1) will comply; 2) lacks ability to comply, which requires a detailed statement; and 3) a legal objection that, for some stated reason, there is no obligation to produce the item (CCP §2031.210). Each of these responses have exact language that you must use.
Unless your response contains only objections, you should verify your responses by signing under oath (CCP §2031.250). Below, are modifiable templates that contains the sample language of the Verification and Response to Request for Production, (adapted from the book How to Manage Contested Divorce in California, which is no longer being published).
Service of the Response
Discovery paperwork is not normally filed with the court (Cal. Rule of Court 3.250). The original response and verification must be served on the initiating party by mail or personally, and a copy of the proof of service should be sent to the recipient and the original proof of service must be kept in your file, along with a copy of the response (CCP §2031.260). You must have the documents served either within 30 days from the date the request was personally served on you, or within 35 days if it was served by mail (CCP §1013).
You cannot serve the documents, they must be served by someone who is not a party to the action and over 18 years of age. The person performing the service must sign a proof of service form stating what they served, who it was served on, and the date of the service. Family law forms regarding personal service and service by mail can be found at the links below.
For more information about service, see San Diego Law Library's guide entitled Service of Notice and Other Papers.
The FORM FL-396 Request for Production of Income and Expense Declaration After Judgment is used to help determine whether to ask the Court for a modification of child, spousal, or family support. Each party may use this procedure once a year after judgment even though no legal matter is pending.
A blank FORM FL-150 Income and Expense Declaration MUST be served with the above FL-396 form. This is the actual document you are requesting that the other party fill out. You must have both forms served on the other party.
Service of the Request for Production of Income and Expense Declaration After Judgment
Just as with all other paperwork in a legal case, you cannot serve the documents. The documents must be served by someone who is not a party to the action and over 18 years of age. The FL-396 form actually contains a Proof of Service declaration on the second page, so an additional proof of service form is not required. The person performing the service must sign the Proof of Service on the FL-396 form stating that they served the FL-396 form and a BLANK FL-150 Income and Expense Declaration, who it was served on, and the date of the service. For more information about service, see San Diego Law Library's guide entitled Service of Notice and Other Papers.