Plaintiff objects to Definition No. Florida Rule of Civil Procedure 1.370 provides that a party may serve upon any other party a written request for the admission of the truth of any matters set forth in 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). 8. Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident. WebFLORIDA RULE OF CIVIL PROCEDURE 1.380: The language of Fla. R. Civ. 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. 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. The applicable general objections, as stated above (General Objections), are incorporated into each of the specific objections and responses that follow. 5. Compliance with Request. 1. Plaintiff further objects to this definition to the extent that it uses the undefined term "during." Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. USE OF FORM REQUESTS. WebRequests for Production Like interrogatories, requests for production are made in writing, they must be answered within 30 days and they are only between the parties. 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. 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. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. 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. P. 1.350(b). Each request is restated below, along with any applicable objections. If a deponent fail s to answer a question propounded or submitted under rule 1. This Standard Document has integrated drafting notes with important explanations and drafting tips. is purposefully implementing that plan in good faith. [CCP 2033.010.] Plaintiff objects to Instruction No. Documents already produced will not be produced again. 3. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. 6. P. 1.350 (b) (amended eff 10/28/21). See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. &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 Instruction No. A party should, without having to be asked, promptly produce any responsive documents discovered after the original production. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. Please produce any and all correspondence or similar communication between any parties to this action. If an objection is made only to part of a demand, the objectionable section must be specified. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. A party who has responded to a request for production with a response that was complete at the time it was provided is under no duty to supplement the response to include after-acquired documents. 22. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 1. P. 1.350(b). Proc., 2033.030(b).) Administrative Procedures for Electronic Filing (PDF), Handbook for Trial Jurors Serving in the United States District Courts (PDF), Plan for Qualification and Selection of Grand and Petit Jurors (PDF), VII. Document Production in International Arbitration - Reto Marghitola 2015-10-20 Because document production can discover written evidence that would otherwise not be available, it is If an objection is made to part of an item or category, the part shall be specified. Requests for Production United States District Court Southern District of Florida. 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. 3 to refer to "Civil Investigative Demand No. 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. The authorities cited in this At A Glance Guide are current as of the publication date. 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. P. 1.350(b). All documents reflecting any verbatim statement of a third party. Therefore, there are no "statements" as that term is defined. These interviews were conducted by attorneys and staff of Plaintiff. In that event, the interrogating party may ask the Court to review the propriety of the. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). 310 or 1.320, or a corporati on or other entity fails to Call the civil clerks office of your court to ask when Motion day is. Share sensitive information only on official, secure websites. 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. 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. 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. 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. 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. 3 to refer to "Civil Investigative Demand No. 8. documents, tapes and records they have about your case. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. 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 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. 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. Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiffs Complaint. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. _ yuj You will likely be asked to provide a long list of answers and fetch a lot of documents. 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. 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. A party objecting to a request for production must provide the reasons for the objection. Fla. R. Civ. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. 21. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. Plaintiff further objects to this request, whether broadly or more narrowly construed, to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. The producing party shall designate one of its regular employees to instruct the interrogating party on the use of the records retention system involved. 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 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. 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. Fla. R. Civ. 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. 2. Plaintiff further objects to Definition No. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." 4. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. WebSample Objections To Request For Production Of uments that. Responding to such requests and interrogatory would be oppressive, unduly burdensome, and unnecessarily expensive, and the burden of responding to such requests and interrogatory is substantially the same or less for Defendant as for Plaintiff. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. Civil Investigative Demand Number 13009 was not an investigation, it was a document request. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. Fla. R. Civ. 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 requests that the following documents be produced at the law offices of the undersigned within 30 days. Please keep this in mind if you use this service for this website. Plaintiff will make available for inspection at Plaintiff's offices responsive documents. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. While "CID" is defined to refer to "Civil Investigative Demand No. IH55J6FL"B]Wsng@i! {.C6. Secure .gov websites use HTTPS Responses to Interrogatories and Requests for Production of Documents 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. As computerized translations, some words may be translated incorrectly. 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. we will unquestionably offer. Plaintiff objects to Definition No. Please produce any medical or employment records you have obtained relating to the Plaintiff. 59 0 obj <> endobj 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. Plaintiff objects to each instruction, definition, and document request 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. Plaintiff objects to this document request to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. 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. The process can be very difficult, for all parties involved. Stated specifically that no responsive documents have been found. Attorneys are reminded that informal requests may not support a motion to compel. 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. (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. REQUEST FOR PRODUCTION OF DOCUMENTS . 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. It is not not far off from the costs. WebObjection to SUBPOENA NO. This disclosure will allow Defendant to identify those individuals from whom it needs detailed information. 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. Web4. 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. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. . 2 regarding "DOJ." Plaintiff will construe "during" to mean "in the course of.". If an objection is made only to part of a demand, the objectionable section must be specified. 4. we will unquestionably offer. 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. 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. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. 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. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to Plaintiffs Complaint or response to the Complaint. 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. 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. 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. Request for Admission: a written statement that must be admitted or denied. 2. Fla. R. Civ. Webthose all. 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. Produced the documents themselves (or copies), specifically identified those documents that are being or will be produced, or specified precisely where the documents can be found and when they can be reviewed; if the documents will be produced, the response should state a specific date when the responsive documents will be available. among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 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