I need help rewording my legal document:

The Plaintiff, Samuel Shealy, in the above case request that the Defendant(s), Harry Stamper and Stamper's Oil Rig, Inc to respond and produce and permit the undersigned, or someone acting on their behalf, to inspect and/or copy the following documents or materials within thirty (30) days from the date of this request. These requests shall be deemed continuing and require supplemental response if the Defendant(s) obtains further documents or materials between the time of production and the time of trial. If in responding to these Requests for Production, the Defendant or counsel withholds production of any document, etc., on the ground that it is privileged, please state with respect to each such document:

A. The type of document involved and a general description of its contents

B. The name, business and/or residence address, telephone numbers and positions of the individual from which the document(s) emanated;

C. The name, business and/or residence address, telephone numbers and position of each individual to whom the document(s) or copies thereof was sent;

D. The date of document(s);

E. The privilege(s) upon which the Defendant relies in withholding the document(s); and

, F. The facts upon which the Defendants rely in support of their claim that the document is privileged.

DEFINITIONS OF TERMS USED HEREIN

1. Defendant: As used herein the term "Defendant(s)" means, Harry Stamper and Stamper's Oil Rig, Inc., their departments, agencies, and subdivisions, their employees, and their attorneys, investigators, brokers, agents, or any other representatives. 2. Accident: Unless otherwise defined in a specific request, the term "accident" as used herein, means the accident occurring at or about December 1, 2019, in South Carolina between Harry Stamper and Samuel Shealy, hereinafter referred to as "Mr. Stamper" as the owner of Stamper's Oil Rig, Inc. 3. Sales Report: The term "sales report", as used herein, unless otherwise defined in a specific request herein, means the comprehensive record of all the sales activity that took place before, during, and after the accident occurred at Stamper's Oil Rig, Inc.

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.