For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. WebREQUESTS FOR PRODUCTION 1. In the course of its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff interviewed a number of individuals, but interviewed none pursuant to Civil Investigative Demand Number 13009, a document request issued to Dentsply. Plaintiff further objects to this interrogatory as vague, ambiguous, overbroad, and unduly burdensome to the extent it asks Plaintiff to identify in detail "all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter." Plaintiff further objects to this definition to the extent that it uses the undefined term "during." P. 1.350(b). Our goal is to help people in the best way possible. WebSample Objections To Request For Production Of uments that. All documents reflecting any verbatim statement of a third party. The producing party shall designate one of its regular employees to instruct the interrogating party on the use of the records retention system involved. 2: All business licenses currently standing in your name or for any entity for OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. 4. All documents obtained by the DOJ pursuant to its CID investigation of Dentsply's distribution and marketing of artificial teeth. Therefore, given the ongoing discussions about the scope of the privilege log and Plaintiff's objections to a request for such a log, Plaintiff will not produce a log of this material at this time. Plaintiff objects to Definition No. You must file the originals of these forms with the 2. 5. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. Plaintiff obtained any responsive information, other than the information that Defendant may derive from the materials described in the preceding paragraphs, from interviews of individuals by attorneys and staff of Plaintiff. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp entities owning the property where the plaintiff was injured, as described in the Complaint. A party should, without having to be asked, promptly produce any responsive documents discovered after the original production. WebOBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. endstream endobj 63 0 obj <>stream "During" can be construed to mean "at the time of," instead of "in the course of." Fla. R. Civ. may be obtained only as Fla. R. Civ. P. 1.280(b)(5). 5. Copies of certain materials, including internal memoranda to which documents obtained from outside parties may have been attached, are circulated to and may be maintained in files kept in Antitrust Division files other than the principal investigatory and case files. USE OF FORM REQUESTS. Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests or responses thereto to be relevant or material to the subject matter of this action. Therefore, there are no "third part[ies]" as that term is defined. Web4.In producing documents requested herein, please produce documents in full, without abridgement, abbreviation or expurgation of any sort. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 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. 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. 1: All documents reflecting any statement of a third party to Use the following instructions to complete the Request for Production of Documents on page 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. For example: P. 1.280(e). 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 document request to Civil Investigative Demand Number 13009 itself. is purposefully implementing that plan in good faith. 2 regarding "DOJ." 3 to refer to "Civil Investigative Demand No. For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. See Federal Rule of Civil Procedure 33(d). Responses to Interrogatories and Requests for Production of Documents Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. 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. The Definition is overbroad and unduly burdensome to the extent it attempts to extend the scope of this document request to documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case. %PDF-1.5 % The party serving the request for production may move for an order compelling production under Rule 1.380. Web Produce documents, information, or objects, or to permit inspection of premises, is the AO 088B. WebAsk the judge to order the plaintiff to give you the documents you requested. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. (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. 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. 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. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." 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. 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 objects to this document request as vague and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Defendant's Second Request for Documents and First Set of Interrogatories. Plaintiff objects to Definition No. SUPPLEMENTATION OF DOCUMENT PRODUCTION. All expert reports from any experts who will testify at trial. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). P. 1.350(b). In addition, such materials often summarize the reasons the Division conducted the interview, characterize the importance of the information learned in the interview, draw inferences based on that information, describe the author's impressions concerning the cooperativeness, credibility, or knowledge of the interviewee, and/or identify potential areas of further inquiry. 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. 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 document request to Civil Investigative Demand Number 13009 itself. P. 1.380(b)(2). 8 regarding documents "in your possession, custody, or control" and "created, transmitted, or received by you" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. Secure .gov websites use HTTPS Documents already produced will not be produced again. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. This Standard Document has integrated drafting notes with important explanations and drafting tips. 21. endstream endobj 123 0 obj <>stream Therefore, there are no "statements" as that term is defined. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. The authorities cited in this At A Glance Guide are current as of the publication date. A specific response may repeat a general objection for emphasis or some other reason. Web20. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. The failure to include any general objection in any specific response does not waive any general objection to that request. 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 Objections to requests for production should be specific, not generalized, and should be in compliance with the provisions of. Timothy J. Corrigan, Chief United States District Judge Elizabeth Warren, Clerk of Court. When producing documents, the response must include an accompanying A specific response may repeat a general objection for emphasis or some other reason. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. If an objection is made only to part of a demand, the objectionable section must be specified. By making the accompanying responses and objections to Defendant's requests for documents and interrogatory, Plaintiff does not waive, and hereby expressly reserves, its right to assert any and all objections as to the admissibility of such responses into evidence in this action, or in any other proceedings, on any and all grounds including, but not limited to, competency, relevancy, materiality, and privilege. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. 3 to refer to "Civil Investigative Demand No. A sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other tangible items from another party. 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 materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 5. &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` _@@ Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise. Plaintiff will use the definitions of these terms found in Objections 3-4 in responding to this request. 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. All such documents and information will not be produced. P. 1.350(b). 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. Plaintiff objects to Definition No. Plaintiff objects to Instruction No. 3. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. Plaintiff will treat this request as if it called for documents (1) that contain, include, or are derived from any statement made by a third party to the DOJ and (2) that were signed and/or adopted, formally or informally, by that third party. 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. Plaintiff further objects to Definition No. While "CID" is defined to refer to "Civil Investigative Demand No. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." The Definition is overbroad and unduly burdensome to the extent it attempts to extend the scope of this document request to documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case. 1) Overly broad 2) Unduly burdensome 3) Overly Costly 4) Repetitive or already in plaintiff's possession custody or control 5) Attorney-client privilege 7. 5. 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. Furthermore, Defendant has access to the addresses and/or telephone numbers of those persons listed on Plaintiff's Rule 26(a)(1) Initial Disclosures and can seek information by addressing formal or informal discovery directly from those entities. Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. 76 0 obj <>/Filter/FlateDecode/ID[]/Index[59 31]/Info 58 0 R/Length 87/Prev 100751/Root 60 0 R/Size 90/Type/XRef/W[1 2 1]>>stream Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails and recordings (tape, disc or other) of oral communications. 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. 7. Nor have such notes and/or memoranda of interviews been seen by anyone other than the case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. Documents already produced will not be produced again. As stated hereinabove, the Subpoena may seek production of documents containing proprietary or privileged business, confidential or personal information of other clients of RACHLIN which has been submitted to RACHLIN in confidence. It can be a long and tedious process, with much of it occurring outside of the courtroom. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 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 Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. Please produce any and all insurance policies that relate in any way to the allegations in Plaintiffs Complaint or incidents referred to in Plaintiffs Complaint. 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 endstream endobj startxref HW[O#7~1d. 89 0 obj <>stream Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests and interrogatory, and responses to the requests and interrogatory, to be relevant or material to the subject matter of this action. The producing party shall make available any computerized information or summaries that it either possesses or can produce by a reasonably efficient procedure. Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope. Responding to such requests would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of responding to such requests is substantially the same or less for Defendant as for Plaintiff. An attorney's promise that documents will be produced should be honored. Plaintiff objects to each document request that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. %%EOF 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 Arnold z Ferguson WebWhere To Download Sample Objections To Request For Production Of Documents Requests must be clear and concise, and request that the If an objection is made only to part of a demand, the objectionable section must be specified. Outside of the publication date endobj startxref HW [ O # 7~1d `` CID investigation. the use the. 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