Requests for Production can be served either on a party to the litigation, or on a “non-party.” (A non-party, for discovery purposes, is any party that is not a plaintiff or a defendant in the pending lawsuit). In personal injury cases, for instance, the defendant’s insurance company (through the defense attorney) will almost always want to obtain the injured plaintiff’s medical records and medical bills from the injured plaintiff’s doctors and other medical care providers. The reason is obvious and legitimate: to properly evaluate an injury, the insurance company must have all of the relevant information regarding the diagnosis and treatment of that injury. Where those records are sought directly from the doctor (as opposed to getting them directly from the injured plaintiff’s attorney), there is a set of rules that must be followed.