With the reform of civil procedure law in 2002, Section 142 of the ZPO underwent changes. According to the newly formulated wording of the provision, the submission of documents can now be ordered not only against the party bearing the burden of proof but also against the party not bearing the burden of proof, who has not referred to the document. The law does not provide for any rights of refusal. Such an extensive obligation to submit documents was previously unknown in German civil procedure law. Rather, the principle was that no party is obliged to advance the case of their opponent. Furthermore, the conditions under which an obligation to submit documents may arise for the opposing party remain largely unclear. There is also the question of whether this obligation to submit documents unduly undermines the parties' control over the factual material in favor of an official investigation of the facts. The study concludes that under the previous legal situation, Section 142 of the ZPO must be interpreted restrictively. Only in the event of an alignment of Sections 422 and 423 of the ZPO de lege ferenda would a literal interpretation be possible.