Elleby v. Forest Alarm Service, Inc., 2020 IL App (1st) 191597: Understanding Document Request Requirements in Illinois

Document requests are a critical component of the discovery process in legal proceedings, enabling parties to obtain essential evidence and information to support their cases. The case of Elleby v. Forest Alarm Service, Inc., 2020 IL App (1st) 191597, offers valuable insights into the requirements and intricacies of document requests in Illinois. In this blog post, we will delve into the Elleby case and explore the key elements and considerations involved in making effective document requests.

Background of the Case

Elleby v. Forest Alarm Service, Inc. stemmed from a workplace injury lawsuit. The plaintiff, Elleby, alleged that Forest Alarm Service, Inc. was responsible for his injuries and sought access to specific documents to support his claim. The case brought to light important questions about the adequacy and specificity of document requests in Illinois.

Key Requirements for Document Requests

  1. Relevance: The first and foremost requirement for a document request is that the requested documents must be relevant to the case. Parties should carefully consider how each document sought pertains to their legal claims or defenses. Irrelevant requests may be challenged by the opposing party.
  2. Specificity: Document requests must be clear and specific. Ambiguity can lead to disputes and delays. Elleby v. Forest Alarm Service, Inc. emphasized the importance of crafting precise requests that leave no room for confusion. Vague requests may be met with objections.
  3. Identification: It’s crucial to identify the documents sought with as much detail as possible. This may include specifying document types (e.g., emails, contracts, medical records), dates, authors, recipients, and any relevant subject matter. The more information provided, the easier it is for the responding party to locate and produce the requested documents.
  4. Reasonable Scope: Document requests should have a reasonable scope, balancing the need for information with the burden of producing documents. In Elleby, the court emphasized that overly broad or burdensome requests may be subject to objection. Parties should aim for a scope that is proportional to the case’s complexity and significance.
  5. Privilege and Confidentiality: Parties must be aware of and respect attorney-client privilege, work-product doctrine, and any other applicable legal protections for certain documents. These protections may shield documents from disclosure unless exceptions apply.
  6. Timing and Deadlines: Parties should adhere to court-ordered deadlines for document requests and responses. Failing to meet these deadlines can result in sanctions or adverse consequences for the non-compliant party.
  7. Cooperation and Communication: Parties are encouraged to cooperate in the discovery process and, if possible, attempt to resolve disputes over document requests through communication and negotiation before involving the court.


Elleby v. Forest Alarm Service, Inc., 2020 IL App (1st) 191597, serves as a reminder of the importance of well-crafted document requests in legal proceedings. To maximize the effectiveness of these requests, parties must ensure that they are relevant, specific, and reasonably scoped. Additionally, parties should be aware of legal protections, deadlines, and the need for cooperation in the discovery process. By adhering to these requirements, litigants can help ensure a smoother and more efficient legal process while enhancing their chances of obtaining crucial evidence to support their cases.

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