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(A) A summons and complaint may be served upon a defendant of any class referred to in paragraph (1) or (4) of subdivision (d) of this rule by mailing a copy of the summons and of the complaint (by first-class mail, postage prepaid) to the person to be served, together with two copies of a notice and acknowledgment
A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
Rule 81 requires use of a special summons which commands that the defendant appear and defend at a specific time and place set by order of the court and informs him or her that no answer is necessary.
Rule 81 requires use of a special summons which commands that the defendant appear and defend at a specific time and place set by order of the court and informs him or her that no answer is necessary.
(A) A summons and complaint may be served upon a defendant of any class referred to in paragraph (1) or (4) of subdivision (d) of this rule by mailing a copy of the summons and of the complaint (by first-class mail, postage prepaid) to the person to be served, together with two copies of a notice and acknowledgment

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Interrogatories, which are written questions about things that are relevant or important to the case. (NRCP 33; JCRCP 33) Requests for production of documents or things, which are written requests that demand the other side provide particular documents or items.
Service. A subpoena may be served by a sheriff, or by his deputy, or by any other person who is not a party and is not less than 18 years of age, and his return endorsed thereon shall be prima facie proof of service, or the person served may acknowledge service in writing on the subpoena.
When a summons is served on the defendant, it must either be served personally, or on a person who is older than 16 at the premises where the defendant is employed or resides. There are exceptions to this rule but for the purposes of a medical malpractice claim, this rule applies.
Hence, under the original wording of Rule 81(c), where a case is filed less than 20 days before the term and is removed within a few days but before answer, it is possible for the defendant to delay interposing his answer or presenting his defenses by motion for six months or more.
The burden of production refers to a partys obligation to come forward with sufficient evidence to support a particular proposition of fact. The burden of production combines with the burden of persuasion to make up the burden of proof throughout a trial.

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