Contract or agreement upon which the debt is based

What is your location as the laws vary by country ?

" [case caption]

DEFENDANT [your name]’S
FIRST SET OF REQUESTS FOR PRODUCTION

TO: [name of Plaintiff]

Defendant hereby requests, pursuant to the _____ Rules of Civil Procedure, and to Rule __ in particular, that you produce copies of the following documents, within ___ days (whatever the pertinent rule provides] after the service hereof:

1. contract or agreement upon which the debt is based
2. ...
...
DATED ___________.

_________________________
Your name, address & phone number, Defendant"

Insert other things you want produced. You should ask for everything you think you may need the first time.

Citing the rule is not necessary, but it doesn't hurt.