Notice to Produce in a Forfeiture Case
In a forfeiture case, the agency might send you a request to produce. The number of state-level seizures for forfeiture has increased dramatically over the last several years. The attorneys at Sammis Law Firm focus on these complicated cases.
Not only can the claimant be served with a request to produce documents, but the claimant can also file a request to produce documents on the seizing agency.
This is an example of a request to produce in a case involving the seizure of U.S. Currency in Lee County, FL.
IN RE: FORFEITURE OF $______ US CURRENCY
CASE NO. 25-CA-00XXXX
PETITIONER’S REQUEST TO PRODUCE TO THE CLAIMANT
TO: Claimant, __________
REQUEST PROPOUNDED BY: Petitioner, Carmine Marceno, as Sheriff of Lee County, Florida
YOU ARE HEREBY notified that the aforementioned propounding party, by and through the undersigned attorneys, and in accordance with the applicable Rules of Civil Procedure, requests the party named above to produce to the Petitioner at the law offices of Henderson, Franklin, Starnes & Holt, 1715 Monroe Street, Fort Myers, Florida, within 30 days of the date of this request, for the purposes of inspecting and copying, the items described in the attached list.
Petitioner would state that it has a need to examine, copy, and inspect said described items and are unable to obtain said described items by other means, or, alternatively, Petitioner is otherwise entitled to said items under the applicable Rules of Civil Procedure and case law interpreting same.
DEFINITIONS
The following definitions shall apply:
A. “Claimant” or “You” means [name of claimant] and any employee, agent, investigator, or attorney, or other persons acting for or on behalf of Claimant or under Claimant’s authority and control individually, jointly, or in any capacity whatsoever from whom discoverable information may be obtained.
B. “Documents” is synonymous in meaning and equal in scope to the data, information, and things discoverable under Rules 1.280 and 1.340, and expressly includes, but is not limited to, writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations stored in any medium from which information can be obtained either directly or, if necessary, after translation by Claimant into a reasonably usable form. Documents include all drafts or duplicates of responsive documents, things, or files.
C. “Communication” means any written or documented statement, dialogue, colloquialism, discussion, conversation, agreement of any kind, including electronic text messages and emails.
D. “Person” means any natural person, individual, proprietorship, partnership, corporation, association, organization, joint venture, firm, other business enterprise, governmental body, group of natural persons or other entities.
E. “Relate” means regarding, respecting, are associated with, or are connected to, whether directly or indirectly. This terms also includes alludes to, responds to, is connected with, concerns, discusses, describes, depicts, evidences, or pertains to.
F. “Related” means with regard to, with respect to, associated with, or connected to, whether directly or indirectly. This term includes alluding to, responding to, connected with, commenting on, concerning, discussing, describing, depicting, evidencing, or pertaining to.
G. “Refer to,” or “pertain in any manner to” shall mean to make a statement about, discuss, describe, reflect, constitute, identify, deal with, consist of, establish, compromise, list, evidence, substantiate or in any way pertain, in whole or in part, to the subject. H. As used herein, the singular and masculine of noun and pronoun shall embrace and be read and applied as a plural or feminine, neuter, as circumstances may appropriate.
REQUEST FOR PRODUCTION OF DOCUMENTS
1. Copies of any and all documentation to support or verify the assertion that portions of the currency that is the subject of this action were purchased online, including but not limited to, receipts and invoices.
RESPONSE:
2. Copies of any and all written wills or other instruments to support or verify the assertion that portions of the currency that is the subject of this action were obtained by inheritance.
RESPONSE:
3. Copies of any and all documentation related to the sources from which you obtained the $_____ U.S. Currency, which is the subject of this action.
RESPONSE:
4. Copies of Claimant’s income tax returns for the five years prior to the date of the seizure through the present date, together with Claimant’s W-2 statements if employed by others or supporting documentation if self-employed.
RESPONSE:
5. Copies of any and all documentation related to the purchase or acquisition of the seized property.
RESPONSE:
Contact an experienced civil asset forfeiture attorney to discuss a seizure under the Florida Contraband Forfeiture Act. Attorney Jason Sammis and Leslie Sammis are experienced in fighting these cases. We can help you demand an adversarial preliminary hearing (APH) or file an answer to any complaint for forfeiture.
To discuss your case, call 813-250-0500.
This article was last updated on Thursday, May 22, 2025.