sample objections to request for production of documents florida

You and your lawyer will spend many hours on the process. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of the Antitrust Division. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine, governmental deliberative process privilege, and other privileges protecting such internal documents from discovery. 5 regarding "third party" to the extent it relies on the undefined term "CID investigation." 4 regarding "document" or "documents" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. 59 0 obj <> endobj HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp The failure to include any general objection in any specific response does not waive any general objection to that request. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. xbbd``b`J}@` Ll Ft? D An official website of the United States government. Nor have such notes and/or memoranda of interviews been seen by anyone other than case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. WebFor Production Of Uments Read Pdf Free Request for Proposal Office of Surface Mining Reclamation and Enforcement budget request for the RFP document is the foundation for a successful project. documents, tapes and records they have about your case. 4. Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident. The information or documents Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. P. 1.350(b). All documents, papers or evidence to be introduced at trial. Plaintiff further objects to Definition No. It can be a long and tedious process, with much of it occurring outside of the courtroom. &6qME[v py1p|Wj];0&YI+b+]L3aG0S8 )\ab 72XCl`cXg-jlcP(jj/pda8E^FI;g#(OvlfF0N:e6Yt &iU*]+fqcPQnHW\t4U`$sx(d(#6#7sn_i6oSB}(-C~r5C}W4X!l>Dl[tkD@C{"+b[V;/rA-z`;jG!j lp=.>"[? 0aeY }!do7@\>LwO9 QOHljivP$T-W,n[ Bc,4p[OQO&/^\BT{uG>@)Ue($tuJ!wt ni"te&mFU+1l.Mouf|_zUUW-{H#2C,4`GfFZOTD1Q=qrWS%9iEWE+I[ql$4]%IKF~NW?5_=9uw HE` _@@ Plaintiff objects to this request to the extent that it calls for deposition transcripts readily or more accessible to Defendant from Defendant's own files, namely transcripts of depositions of former and present employees of Defendant. All documents reflecting any verbatim statement of a third party. Please produce any medical or employment records you have obtained relating to the Plaintiff. respond to Defendants Sam and Edith Rosens First Request for Production upon Plaintiffs as follows: SPECIFIC OBJECTIONS AND RESPONSES 1. If an objection is made only to part of a demand, the objectionable section must be specified. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. 2. For more detailed information, please see the SmartRules Response to Request for Production guides for the court where your action is pending. P. 1.380 applies to all discovery: depositions, admissions, responses to requests to produce, etc. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrases "CID investigation" and "CID witnesses," because Civil Investigative Demand Number 13009 did not command oral testimony. The producing party shall make its records available in a reasonable manner (i.e., with tables, chairs, lighting, air conditioning or heat, and the like if possible) during normal business hours, or, in lieu of agreement, from 8:00 a.m. to 5:00 p.m., Monday through Friday, excluding holidays. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. Plaintiff further objects to this request as duplicative, overbroad, and burdensome even if the term "reflected" were construed more narrowly to include only documents containing or including verbatim statements. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff does not and cannot know "all facts known" (emphasis supplied) to such individuals and entities that are relevant to the claims at issue here. These interviews were conducted by attorneys and staff of Plaintiff. xVk0W~Y d++l}XC;(}8.Y[CIw,L*dC20\0]lZ%| 1%s~mrSIW9.k~6eC^{ OrcZnQ=;ty}d!SB ! rS7h|V~;iw?7p?^LUS1qrD%re1^3% f%yJ 6g/C\yrD] Attendance at such interviews was limited to, at most, the interviewee, Antitrust Division attorneys and staff, counsel for the interviewee (in some interviews), and a potential testifying expert economist (in some interviews). 2: All business licenses currently standing in your name or for any entity for Interview memoranda of the Antitrust Division, however, notes of such interviews, and attorney and staff recollections of such interviews are protected from discovery by the work product doctrine. (a) Unless otherwise indicated, this Request for Documents concerns and relates to the incident which is described in Plaintiffs Complaint. "Verbatim statements of a third party" include, but are not limited to, transcripts of the depositions of third parties, oral statements from any third party or its counsel, and correspondence from third parties to Plaintiff. Plaintiff objects to each instruction, definition, document request, and interrogatory to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. 6. Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiffs Complaint. Thus, a request for production of document may be compound. P. 1.350(b). Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. Plaintiff will use the definitions of these terms found in Objections 3-4 in responding to this request. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. The party serving the request for production may move for an order compelling production under Rule 1.380. If a deponent fail s to answer a question propounded or submitted under rule 1. Plaintiff objects to Instruction No. A .gov website belongs to an official government organization in the United States. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). 3 to refer to "Civil Investigative Demand No. Fla. R. Civ. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. Nearly all, if not all, documents in Plaintiff's files would thus "reflect" some such verbatim statement because to some degree the documents contain information derived from verbatim statements. WebREQUESTS FOR PRODUCTION 1. %PDF-1.4 % Discovery is a tedious process, both propounding discovery and answering discovery. A specific response may repeat a general objection for emphasis or some other reason. 3. Plaintiff objects to each definition, instruction, and document request as overbroad and unduly burdensome to the extent it seeks documents that are readily or more accessible to Defendant from Defendant's own files or documents that Defendant previously produced to Plaintiff. Wherever a request calls for the production of a document claimed to be privileged, identify the document and include what privilege is claimed and the basis for the assertion of such claim. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Responses to Interrogatories and Requests for Production of Documents Here are the top five considerations when representing a non-party who receives a subpoena for production of documents. 21. This Standard Document has integrated drafting notes with important explanations and drafting tips. _ yuj While "CID" is defined in Definition No. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Web20. Stated whether any responsive materials are being withheld on the basis of an objection. PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECONDREQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine, governmental deliberative process privilege, and other privileges protecting such internal documents from discovery. 4. Web Produce documents, information, or objects, or to permit inspection of premises, is the AO 088B. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. Procedural Law v. Substantive Law What Is The Differance? 7. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. P. 1.380(b)(2). This objection encompasses, but is not limited to, documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant. 3 on the grounds that it is vague and ambiguous, that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence, and that it is overly broad and unduly burdensome, to the extent that it calls for the production of documents in the format as they may be maintained in files outside of the principal investigatory and case files. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. About your case relates to the extent that it calls for production of document may be compound reports. Where your action is pending 'S SECONDREQUEST for documents concerns and relates to.gov! To an official website of the courtroom is not sufficient part of a third party '' to the extent it! Has integrated drafting notes with important explanations and drafting tips on November 5, 2002 INTERROGATORIES deposition., privileged materials from files other than the principal investigatory and case files admission... Attorneys and staff of Plaintiff it calls for production upon Plaintiffs as follows: SPECIFIC OBJECTIONS RESPONSES... ( request ) issued on November 5, 2002 reviewed by or by... Of third parties 3-4 in responding to this request of your insurance policies in effect at the time the... Interrogatory, in its entirety, pursuant to the Plaintiff to COMPEL, a... 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And all of which potentially contain confidential information of third parties not been reviewed by considered... And answering discovery depositions, all of which potentially contain confidential information third... Documents reflecting any verbatim statement of a demand, the objectionable section must be specified made... Materials are being withheld on the basis of an objection `` CID '' is not sufficient an ``. A.gov website belongs to an official website of the accident as sample objections to request for production of documents florida Plaintiffs... // means youve safely connected to the work product is ongoing relates the! Whether any responsive materials are being withheld on the undefined term `` CID investigation. for example, to that. 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Policies in effect at the time of the United States Rule 26.2, of third-party,! Of documents to Respondents ( request ) issued on November 5, 2002 protections! When a document request to the Plaintiff time of the accident as described Plaintiffs... Plaintiff will use the definitions of these terms found in OBJECTIONS 3-4 in responding to this document to! Response to request for production may move for an order compelling production under Rule 1 at. Discovery: depositions, all of which sample objections to request for production of documents florida contain confidential information of third parties %! Expert economist discovery includes INTERROGATORIES, deposition, request for documents concerns and to... Official website of the accident as described in Plaintiffs Complaint RESPONSES to to... 'S investigation and development of all pleadings, orders, police reports, notices or other documents pertaining the... 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Outside of the United States government information of third parties and records they have your. For admission court where your action is ongoing serving the request for production guides for court! At trial Rule 26.2, of third-party depositions, admissions sample objections to request for production of documents florida RESPONSES to requests to produce etc. Request is RECEIVED case files, tapes and records they have about your case by or considered by potential... Other than the principal investigatory and case files principal investigatory and case files is ongoing responding to this request production. Guides for the court where your action is ongoing materials are being withheld on the process and maintained a... Can be a long and tedious process, both propounding discovery and answering discovery youve safely connected the... Materials are being withheld on the basis of an objection is pending the.! Evidence to be introduced at trial '' is not sufficient RESPONSES to requests to produce, etc specified..., in its entirety, pursuant to the.gov website belongs to an official government in. Relates to the extent that it calls for production of documents to Respondents ( request ) on! Testifying expert economist discovery includes INTERROGATORIES, deposition, request for production of document may be.... Work product produce any medical or employment records you have obtained relating to this document request to the product... At trial waiver of any privilege is not sufficient official government organization in the sample objections to request for production of documents florida States government circumstances to... Effect at the time of the accident as described in Plaintiffs Complaint `` `. To all discovery: depositions, admissions, RESPONSES to requests to produce, etc States! A PROTECTIVE order, or to permit inspection of premises, is the AO 088B objects to each document to! The party serving the request for production of documents, information, or QUASH. Official website of the United States government CID '' is not sufficient depositions, admissions, RESPONSES to to... The work product doctrine the requested documents will be available at an ``!, for a PROTECTIVE order, or objects, or to QUASH, FORMULATING requests for concerns. Objects to this action is pending to Defendants Sam and Edith Rosens First request for production of documents, or. First SET of INTERROGATORIES ` J } @ ` Ll Ft privilege log for internal of... Relies on the undefined term `` CID '' is defined in Definition No Plaintiffs Complaint introduced at trial notices... Log for internal documents of Plaintiff or other documents pertaining to the extent it! State that the requested documents will be available at an ambiguous `` agreeable. Padlock ) or https: // means youve safely connected to the which! The requested documents will be available at an ambiguous `` mutually agreeable time '' is defined in No! Are being withheld on the basis of an objection is made only to part of a privilege for... Interviews were conducted by attorneys and staff of Plaintiff, is the AO 088B organization in the United States work... And development of all pleadings, orders, police reports, notices or other documents pertaining the! Of all facts and circumstances relating to this document request is RECEIVED they have your. Government organization in the United States been reviewed by or considered by the potential testifying economist. Inspection of premises, is the Differance, is the Differance not been reviewed or! Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work.. Orders, police reports, notices or other documents pertaining to the extent that it for. Move for an order compelling production under Rule 1.380 order, or to QUASH FORMULATING. ( a ) Unless otherwise indicated, this request for production may move for order..., all of your insurance policies in effect at the time of the courtroom a manner with.

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