help rewording my productions.

REQUESTS FOR PRODUCTION

1. A copy of Mr. Stamper's Oil Rig, Inc. safety book.

2. List of the names who knew about the incident.

3. Medical records showing the injuries of Mr. Shealy that resulted from the incident.

4. Eyewitness statement or surveillance footage of the incident taking place.

5. Any records regarding the plaintiff's medical bill, lost wages, and lost revenue in his business.

6. A form of evidence of Mr. Stamper making the alleged remarks about Mr. Shealy.

7. Footage of Mr. Shealy before the accident using the gym equipment.

8. A sales report with the span of before, during, and after the incident involving the plaintiff.

9. Any records showing Mr. Stamper's negligence of Mr. Shealy's safety and environment. 10. Record of the defendant's behavior during the day of the accident involving the plaintiff.