A request for production asks the other side to produce documents, electronically stored information, or tangible things relevant to the case. Getting the scope right is what determines whether you actually get useful material back.
Define categories, not fishing expeditions
Requests scoped to specific categories, time periods, and subject matter hold up far better than broad requests for 'all documents relating to' a general topic, which invite objections and delay.
Address electronically stored information specifically
Emails, texts, and other ESI often need their own request language addressing format, metadata, and search terms — treating ESI as an afterthought is a common way requests end up producing incomplete or unusable data.
Anticipate privilege objections
Requests likely to sweep in privileged material should be drafted with that in mind, since the response will likely include a privilege log — vague requests make it easier for the other side to over-withhold under a broad privilege claim.
Set a reasonable, defensible timeframe
Requests scoped to the relevant time period of the dispute are harder to object to than open-ended requests spanning years beyond what's actually at issue.