This Practice Note sets out considerations to consider before drafting requests for the production of documents (RFPs) in a federal lawsuit under Rule 34 of the Federal Rules of Civil Procedure (FRCP). Specifically, this Note discusses when counsel should start considering document requests, who can make document requests, to whom the document requests can be made, when to make document requests, and fundamental considerations to keep in mind when preparing to draft an RFP, including determining what documents are needed, why they are needed, and where they can be obtained.