PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECONDREQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 1. WebFLORIDA RULE OF CIVIL PROCEDURE 1.380: The language of Fla. R. Civ. Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiff to reproduce, in narrative answer format, material from third parties that has already been produced to defendant. Any and all land records, contracts, documents or the like reflecting the persons or. 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. As set forth in the correspondence dated March 3, 1999 from Michael S. Spector to Kelly A. Clement, Plaintiff objects to the production of those parties' confidential documents and will not produce those documents unless directed by the Court to do so pursuant to Del. These interviews were conducted by attorneys and staff of Plaintiff. All documents relating to responses or objections to discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. Plaintiff can only know those facts, of which it is aware, that are known to such individuals and entities. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. 2: All business licenses currently standing in your name or for any entity for ih3S@k) \S D/)8?/,F{ lA0(s 8ibsc"! Plaintiff will produce responsive documents only to the extent that such documents are in the possession, custody, or control of the Antitrust Division of the U.S. Department of Justice, as set forth in the Federal Rules of Civil Procedure.Plaintiff's possession, custody, or control does not include any constructive possession that may be conferred by Plaintiff's right or power to compel the production of documents or information from third parties or to request their production from other divisions of the Department of Justice or agencies of the United States. Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. WebThe most essential and detailed information about List Of Objections To Request For Production Florida is listed here by BestProductToday to make it easy for you to pick out what you want to know. Fla. R. Civ. Plaintiff objects to Instruction No. The request is irrelevant to the underlying nature of this proceeding. Upon receiving a document request, counsel should promptly confer with the client and take reasonable steps to ensure that the client: understands what documents are requested, has adopted a reasonable plan to obtain documents in a timely and reasonable manner, and. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not If the court issues an order compelling production and the responding party still fails to reply, that party may be held in contempt of court and may face sanctions up to and including the dismissal of pleadings. The authorities cited in this At A Glance Guide are current as of the publication date. As computerized translations, some words may be translated incorrectly. See Federal Rule of Civil Procedure 33(d). Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. If a party objects to a request as overbroad when a narrower version of the request would not be objectionable, the documents responsive to the narrower version ordinarily should be produced without waiting for a resolution of the dispute over the scope of the request. 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. While "CID" is defined to refer to "Civil Investigative Demand No. Plaintiff objects to Instruction No. Its more or less what you craving currently. These responses and objections are made without prejudice to, and are not a waiver of, Plaintiff's right to rely on other facts or documents at trial. among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. D. Ct. Local Rule 26.2 or pursuant to a Protective Order entered by the Court. WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. 2. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 4. WebSample Objections To Request For Production Of Documents Pdf upload Arnold z Ferguson 1/1 Downloaded from filemaker.journalism.cuny.edu on February 26, 2023 by The process can be very difficult, for all parties involved. Please produce any and all documents which evince, contain or relate to any statements made by Plaintiff or any other person or any communication by any person at the scene of the store in question. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. Plaintiff objects to Definition No. 1. The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. 0 Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to 6. b``$+@ + 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. 5. Specific objections should This disclosure will allow Defendant to identify those individuals from whom it needs detailed information. Absent compelling circumstances, failure to assert an objection to a request for production within the time allowed for responding constitutes a waiver and will preclude a party from asserting the objection in response to a motion to compel. may be obtained only as 3. Objections to requests for production should be specific, not generalized, and should be in compliance with the provisions of. The applicable general objections, as stated above (General Objections), are incorporated into each of the specific objections and responses that follow. For more detailed information, please see the SmartRules Response to Request for Production guides for the court where your action is pending. Please produce any and all books, documents or other tangible items relating to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). d.) The Subpoena requests production of documents by RACHLIN of its working papers. Its unnecessary to repeat this line for all subsequent requests, although it may be useful to indicate the numbers of the requests covered by the objection. This request, in essence, then, asks for the recollections of the attorneys representing the United States, or of the staff working under their direction, or for information contained in memoranda and notes prepared by those attorneys and their staff. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ To the extent that "during" is intended to mean "at the time of," Plaintiff objects to this definition as overbroad because it would call for materials unrelated to this action. 131 0 obj <>stream OBJECTIONS. If an objection is made to part of an item or category, the part shall be specified. The responsive material includes teeth, shade guides, a video tape and a CD-ROM.Alternatively, Plaintiff will produce copies of the documents, except the teeth, the shade guides, the videotape, and the CD-ROM, all of which will be available for inspection at Plaintiff's offices. 22. Rule 45 (a) (2) provides that the court where the action is pending issues the subpoena, even if the recipient is not located in that jurisdiction. Plaintiff objects to this request to the extent that it calls for documents readily or more accessible to Defendant from Defendant's own files, including without limitation documents produced by the Defendant to Plaintiff. The intent of the Rule is clear, stating, Discovery of facts known and opinions held by experts . endstream endobj 63 0 obj <>stream A party objecting to a request for production must provide the reasons for the objection. Web35 requests that dont relate to the genuineness of documents by simply stating that the requesting party has exceeded the numerical limit. Plaintiff expressly reserves the right to supplement, clarify, revise, or correct any or all of the responses and objections herein, and to assert additional objections or privileges, in one or more subsequent supplemental response(s). OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. Accordingly, Plaintiff objects to this request as overbroad and burdensome. Plaintiff further objects to Definition No. IH55J6FL"B]Wsng@i! {.C6. The producing party shall provide any relevant compilations, abstracts, or summaries, either in its custody or reasonably obtainable by it, not prepared in anticipation of litigation. Web20. An attorney shall review any standard form document request or subpoena duces tecum and modify it to apply to the facts and contentions of the particular case. A party may seek inspection and copying of any documents or things within the scope of rule 12.350(a) from a person who is not a party by issuance of a subpoena directing the production of the documents or things when the REQUEST NO. Plaintiff objects to Instruction No. COME NOW, REDACTED (BAKER), plaintiff in the above-styled matter, and serves the following requests to produce to REDACTED, INC. (you, your or Defendant) pursuant to Rule 1.350. "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. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. When producing documents, the response must include an accompanying 2. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than WebThe request is burdensome and oppressive. Web2. "During" can be construed to mean "at the time of," instead of "in the course of." endstream endobj startxref P. 1.350(b). OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS DOCUMENT REQUEST NO. Without waiving this objection and to the extend I understand this question, a copy of a citation for failure to yield dated January 31, 2014, is provided with these responses. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine and other privileges protecting such internal documents from discovery. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. Contact us today for a free consultation. 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. 2 to the extent that it calls for documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks information that is readily or more accessible to Defendant from Defendant's own files, including, but not limited to, interrogatory answers that Defendant produced to Plaintiff, transcripts of depositions of current or former directors, officers, and employees of Defendant, documents that Defendant produced to Plaintiff, and correspondence and other communications from Defendant to Plaintiff. This objection encompasses, but is not limited to, documents previously produced by Defendant to the Antitrust Division of the Department of Justice during the Antitrust Division's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, and all correspondence between the Plaintiff and Defendant. If it has any documents arguably subject to this requirement but which it declines to produce for some reason, the producing party shall call the circumstances to the attention of the opposing party, who may move to compel. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents, information, and oral testimony and obtained other documents and information without issuance of a CID. For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in which event the reasons for the objection is made to part of an item or category, the part shall be specified. Fla. R. Civ. To the extent this request calls for notes and/or memoranda prepared by the potential testifying expert economist, Plaintiff objects to the request as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to the request, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports set by the Court. WebUnder, Fla. R. Civ. Please produce any and all documents prepared by anyone as a result of tests, inspections or measurements made or taken with respect to the scene of the incident. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." is purposefully implementing that plan in good faith. If an objection is made only to part of a demand, the objectionable section must be specified. 2. 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. While "CID" is defined in Definition No. Copy of marriage certificate if a derivative claim is being made for loss of consortium, loss of service, or any other claim by your spouse as a result of personal WebIn litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. The producing party either must produce the documents or items specified as they are kept in the regular course of business, or must identify them to correspond to the categories in the request. Rule 12.351 - PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION (a) Request; Scope. WHEN PRODUCTION IS LIMITED BY INTERPRETATION. Subject to and without waiver of the foregoing objections, Plaintiff will produce the documents responsive to this request that have not already been produced and are not protected by the privileges listed above. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. READING AND INTERPRETING REQUESTS FOR DOCUMENTS. The failure to include any general objection in any specific response does not waive any general objection to that request. Webc.) PRODUCING BUSINESS RECORDS IN LIEU OF ANSWERING INTERROGATORIES. Attorneys should not make objections solely to avoid producing documents that are relevant to any party's claim or defense and proportional to the needs of the case. Web4. A party objecting to a request for production must provide the reasons for the objection. (c) If you maintain that any of the documents requested cannot be produced by virtue of any claimed privilege or immunity, set forth precisely the grounds for your objection to producing the documents in question. In that event, the interrogating party may ask the Court to review the propriety of the. 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 phrase "CID investigation," unless it is intended to limit the definition of "statement" to any comment, observation, remark, observation, or affirmation, whether in written or oral form, made by a third party to Plaintiff during the Civil Investigative Demand Number 13009 investigation. Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the incident or any person or physical object which relate in any way to the circumstances of the incident. Webthose all. The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. Secure .gov websites use HTTPS Fla. R. Civ. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. > To the extent any of Defendant's document requests or its interrogatory seek documents or answers that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests and interrogatory as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports set by the Court. Discovery is a tedious process, both propounding discovery and answering discovery. 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. Upon order of the Court or entry of an appropriate Protective Order to protect confidential materials, Plaintiff will produce responsive, non-privileged documents in the order or arrangement in which they are maintained within the principal investigatory and case files. The new rule amends Rule 1.280 to require litigants to state the deposition question, interrogatory, or discovery request followed by the answer, objection, or other response when responding to production and admissions requests, written deposition questions, and interrogatories. x!S1_OjVDNBfwLVw\{`fxXtlW?tH>i]SHb/zp1y(({!;je@4I:CR~n3+)(J&Z[n3[~,xG#'ot?IM5 |T.]>D_#bXX?O a}BRa}dwXXP A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these PRODUCING DOCUMENTS OVER OBJECTION. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation" and "CID witnesses." Alternatively, Plaintiff will produce copies of the documents. The failure to include any general objection in any specific response does not waive any general objection to that request. 8. Subject to the above objections, Plaintiff has no responsive documents in its possession, custody, or control, other than those that have already been produced to Defendant and those being produced as verbatim statements of a third party in response to Request No. Webregarding requests for production of documents. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff deposed a number persons pursuant to various CIDs calling for oral testimony. Plaintiff further objects to this request to the extent that it requires the production, prior to the entry of a Protective Order by the Court and prior to instruction from the Court as to production pursuant to Del. 89 0 obj <>stream You will likely be asked to provide a long list of answers and fetch a lot of documents. 5. All of the actual clerical data extraction work shall be performed by the interrogating party unless agreed to the contrary, or unless, after actually beginning the effort, it appears that the task could be performed more efficiently by the producing party. Your response to this request should be periodically supplemented. Plaintiff further objects to this request to the extent that it requires the production, prior to the entry of a Protective Order by the Court and prior to instruction from the Court as to production pursuant to Del. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Plaintiff objects to each instruction, definition, document request, and interrogatory to the extent that it seeks documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. Ensured a reasonable inquiry with those persons and a reasonable search of those places likely to result in the discovery of responsive documents. Fla. R. Civ. Plaintiff objects to this document request as overbroad, burdensome, vague, and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Dentsply's Second Request for Documents and First Set of Interrogatories. Moreover, Plaintiff does not waive its right to amend its responses. A response to a document request or interrogatory stating that objections and/or indicating that documents will be produced shall not be deemed or construed that there are, in fact, responsive documents, that Plaintiff performed any of the acts described in the document request, interrogatory, or definitions and/or instructions applicable to the document request or interrogatory, or that Plaintiff acquiesces in the characterization of the conduct or activities contained in the document request, interrogatory, or definitions and/or instructions applicable to the document request or interrogatory. 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). 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. Plaintiff will make available for inspection at Plaintiff's offices responsive documents. While "CID" is defined to refer to "Civil Investigative Demand No. WebRequest in an Instructed Language Learning Context Pleadings, Minutes of Public Sittings and Documents / Mmoires, procs-verbaux des audiences publiques et documents, Volume 22 (2015)(2 vols) Budget Request for Operating and Capital Funds Occupational Safety and Health Law Code of Federal Regulations FCC Record The Parties currently are in discussions about the appropriate scope of the privilege log. Such materials contain the mental impressions, conclusions, opinions, and legal theories of the Government's attorneys in summarizing the Government's understanding of information obtained in the interview, for instance by the emphasis in memoranda of the specific issues of interest to the Division's legal analysis. 119 0 obj <> endobj Subject to and notwithstanding this objection, Plaintiff will use the more expansive definition of "third party" that it has provided in above Objection 3, and it will treat "statements" as covering those made by the individuals and entities listed in Plaintiff's Rule 26(a)(1) Initial Disclosures during Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. This document is available in two formats: this web page (for browsing content) and. If an objection is made to part of an item or category, the part must be specified. Such materials contain the mental impressions, conclusions, opinions, and legal theories of the Government's attorneys in summarizing the Government's understanding of information obtained in the interview, for instance by the emphasis in memoranda of the specific issues of interest to the Division's legal analysis. hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< 1. 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. Plaintiff will construe "during" to mean "in the course of.". 5. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best , 1999 conference with the Court to review the propriety of the provide the reasons for objection... Have not been reviewed by or considered by the potential testifying expert.... 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