Sample interrogatories and request for production of documents

Discovery can help you get documents and evidence to support your case before you go to court. Federal Rule of Civil Procedure 33 covers interrogatories, and FRCP 36 covers requests for admission. the information or document is relevant, as a waiver of the general or specific objections, or as an agreement that future requests for similar discovery will be treated in a similar manner. Step one: Read the local rules. You have been served with the original of Interrogatories and Requests for Production under I. 12. May 8, 2020 · Request for Production Rules. ASHLEY BURTON- Plaintiff v JAMES KROL- Defendant. Make a list in the template. These interrogatories shall be deemed continuing so as to require This form is a sample letter in Word format covering the subject matter of the title of the form. Interrogatories Interrogatories are written questions that are sent by one party to another. In each instance explain. Rules 26, 33, and 34. 1: All photographs, sketches or diagrams relating in any way to the allegations of the Plaintiff’s Complaint. This request for production may be complied with by mailing copies of the requested documents to Defendant within thirty (30) days of the receipt of. Direct the production, copying reproduction, photographing, testing or sampling of specified documents, objects or tangible things whenever relevant to the subject matter of the action. 1001. Document requests are requests that you provide copies of documents. Baltimore, MD 21202. "Documents" includes electronically stored information like computer files, voice mails, emails, web pages, and text messages. 350 provides that any party may request another party: Interrogatories and requests for admission are additional tools that parties can use to discover information before trial. • Facts supporting damages. Aug 1, 2015 · In the practice of law, interrogatories are the most commonly method used in discovery, or in the effort to obtain information from an opposing party to a lawsuit. The plaintiff requests defendant to respond to the following interrogatories under oath. 220 [“. The doctors’ opinions are based upon their review of the medical records, treatment or examination of the Plaintiff, history taken from the Plaintiff and years of experience and medical training. This form is a sample answer of defendant in response to plaintiff's first set of interrogatories and request for production of documents. This form is a sample letter in Word format covering the subject matter of the title of the form. And even then, the dilatory party may file a motion to extend his time to answer. involuntarily to another, and, if so, to whom, or (4) otherwise disposed or. al number of questions does not exceed 30. You can use more than one. “Defendant” shall mean Santander Consumer USA, Inc. FROM: ISABEL MINUNNI, Plaintiff. 5 Interrogatories and Request for Production of Documents to Lender STATE OF NORTH CAROLINA ORANGE COUNTY IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION [plaintiff]BETTY CONSUMER, Plaintiff, [vs. and to request the inspection of property. Serve document requests early in the case—you will need the evidence to depose witnesses, to prepare your witness to be deposed, and to determine what additional discovery to request. Requests. W. Jan 23, 2024 · The request must be specific so that your spouse can tell exactly which documents or items to produce. The next three sample sets are sent throughout the course of discovery. 302(B) and that are in the possession Form interrogatories are an easy way for parties to ask common questions by simply checking the boxes for the questions they wish to ask. Title: Comprehensive Guide to Florida Sample Letter for First Interrogatories and First Set of Request for Production of Documents Introduction: In the legal process, interrogatories and requests for production of documents are vital tools used during the discovery phase to gather information and For more information on the type of information you can get through these interrogatories, read my article providing Sample Interrogatories in Workers Compensation. Our last module will cover requests for document production and physical and mental examinations. (410)779-4600. You are required to respond to this request no later than thirty (30) calendar days after receipt of this Request for the Production of Documents. The scope of this section is basically determined by the extent of discovery which can be made by the party with the intervention of the court. (410)760-8922 (facsimile) Attorney for the Plaintiff. “Plaintiff” shall mean [Consumer]. No, they are not the same thing. , any type of physical evidence in the other party’s possession or control. Zois 1 South St, #2450 Baltimore, MD 21202 (410)779-4600 (410)760-8922 (fax) These requests apply in Use of Force Cases, Inmate Against Inmate Assault Cases and Disciplinary Due Process Cases, as defined in the form, in which the events alleged in the complaint occurred while the plaintiff was in the custody of the Department of Correction of the City of New York, the New York State Department of Corrections & Community Supervision, or any other jail, prison or - Trial court did not err in entering a default judgment against sellers pursuant to O. [6] [7] This caption should look exactly the same as the caption on every other document. : CASE NO. To the extent any request for production is objected to, please set forth a complete. Message View Profile. You must sign your answers and to to in in objections. CASE NO. Instructions: 1. HAWKINS, M. Respectfully submitted, Miller & Zois, LLC. The primary rule governing requests for production is CR 34. TO: STATE FARM, Defendant. Posted on Mar 27, 2014. and nature. FROM: MARY HAYMAN, Plaintiff. For example, when you send requests for production of documents or interrogatories to the opposing party or you send responses to those requests, you do not file the requests, interrogatories, or the responses with the court. Bar No. Experts must provide their responses in a prompt and timely fashion. In a limited civil case (cases less than $25,000, or $35,000 if filed after Jan. Laura G. If we’re curious about income, we’ll ask for pay stubs and income tax returns. No items have been identified-- after a diligent search-- that This form is a sample letter in Word format covering the subject matter of the title of the form. G. Title: Exploring Georgia: A Comprehensive Guide to Sample Letters for First Interrogatories and Request for Production of Documents Introduction: In legal proceedings within the state of Georgia, parties involved often rely on a set of standardized documents known as "Sample Letters for First Dec 28, 2019 · 1) interrogatories; 2) requests for production of documents and inspection; 3) requests for admissions; 4) depositions; 5) subpoenas duces tecum; 6) physical and mental examinations. the production of documents that were prepared for or in anticipation of litigation, constitute attorney work product, contain attorney-client communications, or are Request for Production of Documents in an auto accident case; Sample Discovery: depositions, requests for admission and other discovery in personal injury cases; More Sample Interrogatories; IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND. the circumstances surrounding the authorization of such disposition thereof, state the approximate. This eleventh edition includes a new chapter on discovery related to commingled assets, updates to the standard and follow-up interrogatories, updates to the forms related to discovery of electronically stored information and the forensic examination of computers, and the current Pennsylvania Rules of Civil Procedure relating to discovery. 2) I have read the foregoing answers to the interrogatories. For each item, write “Response to Request for Production Number” followed by the REQUEST FOR PRODUCTION NO. STATE OF SOUTH CAROLINA ) ) IN THE The party submitting the interrogatories may move for an order under Rule 37(a) with respect to any objection to or other failure to answer an interrogatory. documents not in Plaintiff’s possession, custody, or control; (2) insofar as it calls for. PLAINTIFF’S FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS Definitions and Instructions 1. If you do not attach the copy, describe the document, including its date. Your response(s) and the documents are to be sent to the undersigned at 104 Church Lane Suite 201, Baltimore, Maryland 21208. Note: This is a sample of the Plaintiff’s medical malpractice lawyers request for production of documents in a medical malpractice case. Production will take place at a specified time and place, if you are objecting to the original time and place of production. Any party may, by written request to any other party: 1. About. Davis 12800 Shaker Blvd. Exhibit A is an example of post-judgment interrogatories that might be sent to an individual debtor; Exhibit B lists likely questions that would be asked of a debtor who is a corporation or an LLC; and Exhibit C is an example of requests for production of documents that might follow a final judgment. P. Create your caption. Jan 13, 2022 · Interrogatories are one form of discovery in a lawsuit. Plaintiff requests that documents be produced as they become ready and that defendant does not wait until all documents are ready to start production. 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 (day), (date), at (time),( following service of this Request for Production of Documents), originals or legible copies of the documents and things described below. Sep 24, 2013 · Language has been added to Rule 34(b)(1) to the effect that a request for production "may specify the form in which electronically stored information is to be produced. v. 10. IN THE CIRCUIT COURT FOR MARYLAND COUNTY. I know the contents thereof. “Documents” includes electronic transmission, and writings and recordings as defined in Fed. You are requested to file within thirty (30) days a written response to requests on the attached Document Schedule and to produce those documents for inspection and copying within Mar 27, 2014 · Website. A party may serve on another party–no later than 30 days before the end of the discovery period–a request for production or for inspection, to inspect, sample, test, photograph, and copy documents or tangible things within the scope of discovery. Sep 6, 2022 · INTERROGATORIES AND REQUESTS FOR PRODUCTION TO: DEFENDANT IDAHO WATER RESOURCE BOARD AND TO: COUNSEL FOR DEFENDANT I. Written . Interrogatories are written questions posed to the opposing party, for which a response is required, under conditions specified by the jurisdiction ’s rules of court procedure. You are requested to file within thirty (30) days a written response to this request on the (attached Document Schedule) and to produce those documents for inspection and copying on. ) Someone who receives a Request for Production of Documents has 30 days to provide the documents. Access. Florida Rule of Civil Procedure 1. requests for admissions and requests for production of kelley drye & documents of satellite senior income fund, fund warren llp 11, and deutsche bank trust company americas pait avf1wur newyaoumnywb178 referred to. explain why not. For the purpose of these Interrogatories only, Plaintiff has used the definitions set forth below. 316, 317. ”]. Procedures. ÐÏ à¡± á> þÿ T V This form is a sample letter in Word format covering the subject matter of the title of the form. such as Documents stored on any type of computer, Sample Requests for Production for Social Media Discovery. 12: Any DOCUMENT prepared during the regular course of business as a result of the incident complained of in the PLAINTIFF’S Complaint Requests for production may be used to inspect and copy documents or tangible items held by another party. FIRST SET OF INTERROGATORIES. ) For individuals who do not have a subscription, follow the following guidelines to quickly find and download Sample Letter for First Interrogatories and First Set of Request for Production of Documents: Check out to make sure you have the correct template with regards to the state it’s needed in. g. , Room 400, Washington, D. 8. Cioffi Remmer. Oct 28, 2016 · Sample Interrogatories for Social Media Discovery. These General Objections and Limitations apply to each of Plaintiffs’ Discovery Requests as though restated in full in response thereto. . If asked to IDENTIFY A DOCUMENT, attach a copy of the document, unless you. 2015 October. A. For example, a request for "each and every document supporting Copy the name of the Asking Party, Answering Party, and Set Number from the Request for Production. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of There is a sample request at the end of this. OBJECTION# listed above applies to this request. PLAINTIFF’S REQUESTS FOR PRODUCTION OF DOCUMENTS TO DEFENDANT STATE FARM. date thereof and describe its contents. Evid. Be sure the Interrogatories and Certificate are served on each party. 2 “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and Aug 23, 2023 · Sample Engagement Letter From Retaining Attorney; Sample Engagement Letter From Expert Witness; Federal Rules of Evidence (FREs) Sample Interrogatories and Request for Production to Expert Witnesses ; Evaluation and Use of Visual Aids; Items Required For Testimony; Questions That Experts Should Be Prepared to Answer; Positive Qualities for Jan 18, 2023 · Requests for Documents ("Requests for Production") (The court rule about these is CR 34. Requests For Production. The Legal Help Centers Plaintiff objects to each Request: (1) insofar as it calls for the production of. They quite literally worked as hard as if not harder than the doctors to save our lives. Documents, photographs, and video play an important role in winning your claim for workers comp benefits or negotiating a top-dollar workers compensation settlement. A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing. An experienced personal injury attorney will know how to use dog bite discovery tools like requests for production of documents to collect and assemble that evidence. A. " Rule 34(b)(2)(B) and (C), modeled after Federal Rule 34(b)(2)(D) and (E), have been added to deal with responding to a request for production of electronically stored Gibbon (S. Indeed, the Federal Rules now permit a plaintiff to serve discovery requests 21 days after service of the complaint. The side receiving the request has 30 days to send these documents directly to Request all facts that support each of the claims and allegations contained in the plaintiff’s complaint. Endnote. Any DOCUMENTS identified in any other parties ’ Answers to Interrogatories. 030 (c) (2) ). General Objections 1. Interrogatories are written questions that are answered in writing under oath. First, serve an initial set as well as later “clean-up” set so long as the tot. Please provide a complete copy of the Complainant’s file and any other Below are plaintiffs’ request for production of documents propounded to a dog owner in a dog bite case. Jul 7, 2022 · The primary rule governing interrogatories is CR 33. Request all facts that support the damages that the plaintiff is seeking. Copies of all stock certificates in which you and/or your spouse have or had an Jan 30, 2024 · Unlike the pleadings and motions, discovery materials are not filed with the Court. D. Response - Once you are served a request for production, you are required to submit a written response within the time limit. Typically, if you requested a document, but the other side claims it doesn't exist, you can object to the judge if they try to introduce the document at trial. 2. You can also check out my article on Answering Interrogatories in Workers Compensation Claims for advice. So long as that motion is heard within 30 days of filing, it too can stave off the Drafting discovery documents for effective use at trial. , et al. - Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may be used to the extent permitted by the rules of evidence. 10. Although these requests are most commonly used to obtain copies of documents, they can also be used to test, measure, photograph, etc. A judge once wrote in an opinion, “Ask me a foolish question and I’ll give you a foolish answer. This is the _____ day of January, 2003. Oct 6, 2016 · Local Rules. the document. Title: Understanding Mississippi Sample Letter for First Interrogatories and First Set of Request for Production of Documents Introduction: In legal proceedings, interrogatories and requests for production of documents play a crucial role in gathering information and evidence. A party is not limited to only 30 requests for production of documents. You or your attorney will call to confirm the date and time; otherwise, it will be assumed that you will not comply with this request. Any and all documents which you intend to use or introduce at trial. Provided as requested Not Applicable Will supplement later before trial Requested document is already in the Petitioner’s possession The requested documents exist, but are not in Defendant's custody and are not reasonably available to the Defendant. You are required to produce the following described documents that are or may be within your possession, custody or control. However, this information does not include Advocate’s Interrogatories and Requests for Production of Documents, PA-RDC 113-124 (the “Interrogatories and Requests”) as follows. S. The top of the first page of your interrogatories must include the same caption that appears at the top of the first page of every document that has been filed with the court in your case. There are 4 common ways to do Discovery. Nature and scope. But getting these items can be difficult – especially when the employer and insurer have them and you don’t. PROCEDURES A. DEFINITIONS AND INSTRUCTIONS . Product | Pennsylvania Bar Institute. You need to set your date for production at least 30 days after service of the demand ( CCP §2031. _____ _____ the Court shall address prior to trial the disclosure of such documents to plaintiff for use at trial. Interrogatories are a way to obtain information from the opposing party that may be useful in the lawsuit. 1 South St, #2450. Interrogatories: These are written questions to the other party that must be answered under oath. These interrogatories continue in Mar 2, 2006 · 11. Once the documents are complete, make one copy for each party to the case. Jurisdictions often have their own rules regarding the number of interrogatories. AMANDA STROUD, et al. Below is a sample request for production of documents in a birth injury medical malpractice lawsuit. : C-03-CV-21-00002. The time limit will be the later of: 30 days after you were served with the request for production; OR. Serve the Requests. The Plaintiff incorporates herein by reference all of her medical records attached to the Plaintiff’s response to request for production of documents. J. Request for Production of Documents Malpractice Cap in Maryland (table) REQUEST NO. (415) 944-2456. Aug 24, 2019 · Requests for Production of Documents. R. You absolutely cannot assume that every jurisdiction follows the FRCP as a model (25 interrogatories). Mar 8, 2023 · The party must respond to the discovery request with one of the following prompts: Permitted as requested. For example: “produce your tax returns and W2s for the last five years. R. Request for Production of Documents (pdf fillable) Documents to be identified shall include all those documents in your possession, custody, or control and all of the documents of which you have knowledge. 2: Request for Production of Documents in Virginia Workers Compensation . Give the name, address, phone number, and occupation of the person who has. 2: Any and all documents identified by the Plaintiff in response to the interrogatories propounded by this Health Care Provider. Remember, the Plaintiff must prove 2 things to win a debt collection lawsuit: You owe the debt, and. Be sure to look for: Number of interrogatories. §§ 9-11-33(a)(2) and9-11-34(b)(2 Interrogatories Interrogatories are written questions that are sent by one party to another. Instructions 1. Requested items are being served with the response. interrogatory interrogatories separately 30. Interrogatories under the provisions of Rule 33 and Rule 34 of the NC Rules of Civil Procedure. Copies of all documents which constitute those identified or referred to in the United States’ Interrogatories addressed to you and served simultaneously with this Request for Production of Documents or in the response to those Interrogatories. The term "document" is used in the broadest sense permitted and includes, by way of illustration only and not by way of limitation, the following, whether printed or reproduced by existence, state whether it is: (1) missing or lost, (2) destroyed, (3) transferred voluntarily or. mail they have 7 extra days to respond. 20530, within 30 days of service of these Interrogatories. Title: Demystifying Minnesota Sample Letter for First Interrogatories and Request for Production of Documents: A Comprehensive Guide Introduction: In legal proceedings, a crucial aspect is the exchange of information between parties involved. basis for the objection. Defendants interrogatories form for breach of contract is a crucial legal document used in the litigation process to gather information regarding the breach of contract claim made against the defendants. A request for production, as the name suggests, is a request for another party to produce something, usually copies of documents. Please see Local Rule 26 for definitions. C. 23: All documents concerning claims for personal injuries made before or after the SUBJECT INCIDENT by PLAINTIFF. • Identification of documents supporting claims. (b) Scope; use at trial. (2) when used with respect to a document, means to state (a) the type of document (e. Plaintiff requests that Defendant serve its answers, in writing and under oath, to the undersigned counsel for Plaintiff at 325 Seventh Street, N. DONNA L. : 74918) ^ost Office Box 2980 55 East Camperdown Way, Suite 300 (29601) Greenville, South Carolina 29602 (864) 239-4000 ATTORNEYS FOR DEFENDANT, ANYWARE, LLC D/B/A ANYWARE EXPRESS July , 2018 5 ELECTRONICALLY FILED - 2018 Nov 21 10:35 AM - GREENVILLE - COMMON PLEAS - CASE#2018CP2303185. Y ou must explain why you object. If the response to any of requests 8 through 11 is “None,” that response shall be provided to plaintiff at the time these requests are responded to. RESPONSE NO. 25: YOUR cell phone records, including times Jun 3, 2020 · A request for production makes a formal request for a party to produce documents, electronically stored information, or other information. 15 days after your initial pleading or motion is required. Case No. Drafting RFA’s, interrogatories and requests for production of documents with their use at trial in mind. The term "document" has the broadest meaning accorded to it by Rule 34 of the Jan 22, 2022 · 3. Please provide a complete copy of the Complainant’s file and any other As of the present date, Plaintiff has not yet received executed Answers to Interrogatories, Response to the Request for Production of Documents, or Response to Request for Admissions from the Defendant. this request. INTERROGATORIES 1. ANSWER: Alan . TIMELINE: AFTER INTERROGATORIES ARE SERVED . 24-C-02-00380. This is the first set of requests for production sent out in this lawsuit. Please complete the answers within the space Construction LLC serves the following requests for production of documents on Defendants Base 360, LLC and Nicholas Gilley to be answered separately and fully, in writing and under oath, within thirty (30) days. interrogatories. If you or a member of your family has been injured in a dog attack, please give us a call at (916) 921-6400 or (800) 404-5400 for free, friendly advice. Do not send a copy to the Court. The requests for documents intermingled with the interrogatories herein shall be treated as formal requests for the production of these documents under Rule 34 of the North Carolina Rules of Civil Procedure if voluntary submission of said documents is not obtained. Aug 7, 2023 · These are samples of continuing interrogatories and criminal discovery requests for production of expert testimony by hired or subpoenaed witnesses on specific subject matter or on SOPs of scientific/laboratory analysis and testing. Sep 16, 2020 · 196. Please state the name, address and telephone number of all persons which you consulted in answering these interrogatories. 15. REQUEST FOR PRODUCTION NO. 1 See, e. I. Plaintiff’s First Interrogatories to Defendant . Whether on a form or not, the Request for Production will have a numbered list of documents or items they want you to produce. 11: Any DOCUMENTS received pursuant to a subpoena request in this case. Boehlke (1963) 33 F. 1 Request for Production and Inspection to Parties. The Department objects to each Interrogatory and Request insofar as it seeks production or disclosure of documents that require PWD or Raftelis Financial Consultants Apr 15, 1999 · Defendant. Offers samples for a few select types of litigation but can also act as a template for claims in other practice areas as well. Now comes the Plaintiff, Mary Elizabeth Hayman, by and through her attorneys, Plaintiff Mary Hayman (“Plaintiff”), by and through his attorneys, Miller & Zois, LLC Before you start. Requests for production require the other side to produce documents regarding the case. In most cases, these would be documents that you have under your control or can easily obtain, such as medical bills, pay stubs, proof of lost wages, etc. , CCP § 2031. Plaintiff’s Interrogatories the person to whom these interrogatories are addressed. Rule 2-422. 14. § 9-11-37(b)(2) without conducting a hearing on willfulness because the sellers did not file answers to a broker's request for interrogatories and production of documents within the time period prescribed by O. (a) Request. ) Questions do discovery: (“Written Interrogatories”) (The court rule about these. : 24-C-17-001028 OT. Definitions 1. FORMULATING REQUESTS FOR DOCUMENTS. Apr 11, 2024 · (1) A party may serve on another party a request (a) to produce and permit the requesting party, or someone acting for that party, (i) to inspect and copy designated documents or (ii) to inspect and copy, test, or sample other tangible things that constitute or contain matters within the scope of MCR 2. Jan 30, 2024 · Read the Rule: Md. Oct 30, 2013 · Usually, Requests for Production of Documents go hand-in-hand with interrogatories, because we use them to request the documents that back up the information provided in the interrogatories. URCP 6(c). will be included in the production. 1, 2024) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production of documents. Part VII offers additional Model Discovery. Step two: Go back and read the local rules again. Plaintiff’s Request for Production of Documents to Defendants. The amount of the debt they claim you owe is correct. 1. In the sample above, the first set listed assumes that all 30 interrogatories are asked at one time. 3) The foregoing answers to the interrogatories and responses to requests for production of documents are true, correct and complete. For more information on requests for production of documents see URCP 34. : C-02-CV-16-001864 Apr 19, 2024 · See Part III: Interrogatories and Requests for Production of Documents. requested herein, pursuant to Rule 196. 24: All documents concerning the past or present physical, mental, or emotional condition of PLAINTIFF. 1: REQUEST NO. Interrogatories (pdf fillable) Answers to Interrogatories (pdf fillable) Requests for Production of Documents: This is a request to the other party to provide documents or other tangible things. ] Request for Production of Documents. RESPONSE: 12. Requests for production are the means by which you can ask the other party to make copies of documents, photographs, records, etc. Rule 33 (a) thus gives a party, in the case of original interrogatories, 75 days, and in the case of further answers, 60 days, to file answers before the guillotine can fall. Interrogatories. ”. (“Santander”), including any other name by which it is or was known, and all agents, employees, or persons who act or Generally, a party has 28 days to respond to a request for production of documents, but if the requests were served by U. (Pressley v. (e. An interrogatory is a written question from one party to the lawsuit to another party to the lawsuit (usually, the opposing party). INTERROGATORIES AND DOCUMENT REQUESTS 1. Ask the plaintiff to identify any documents that might support his or her claims. You are requested to file within thirty (30) days a written response to request on the (attached Document Schedule) and to produce those documents for inspection and copying within thirty (30) days of service of this Request at the Law Offices of Miller & Zois, LLC, 1 South St, #2450, Baltimore, MD 21202. Interrogatories are questions that require a written response. letter, memorandum, handwritten note, facsimile, e- -mail) (b) its date of origin or creation; (c) its author and addressee; (d) its last known custodian or locations; and (e) a brief description of its subject matter and size. The timeline below lists what generally happens after Interrogatories are served. In addition to complying with the provisions of Rules 26, 34 and 45, Federal Rules of Civil Procedure, a request for documents, whether a request for production or a subpoena duces tecum, should be clear, concise, and reasonably particularized. Plaintiff Michael Smith, by counsel, requests that Defendant, Anthony Roberts, answer the following Interrogatories under oath and in compliance with Rule 4:8 of the Rules of the Supreme Court of Virginia, subject to the instructions below. ri ad zm sm ud um cp xv bx lb