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. 310 or 1.320, or a corporati on or other entity fails to Fla. R. Civ. 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. Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. 1. 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. D. Ct. Rule 26.2, of potentially confidential materials produced to Plaintiff by third parties. The intent of the Rule is clear, stating, Discovery of facts known and opinions held by experts . 3 to refer to "Civil Investigative Demand No. Further, the incidents are so numerous that it is impossible to name them all; the main ones are related here, but Complainant reserves the right to supplement this WebREQUESTS FOR PRODUCTION 1. Compliance with Request. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." Fla. R. Civ. Plaintiff further objects to this instruction as overbroad and unduly burdensome to the extent it seeks (a) 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, (b) documents previously produced by Defendant to the Antitrust Division of the Department of Justice in the course of the antitrust investigation leading up to the filing of this case, transcripts of depositions of employees and former employees of Defendant, correspondence between the Plaintiff and Defendant, and (c) documents in possession, custody, or control of the Antitrust Division of the Department of Justice and its present officers, employees, principals, officials, agents, attorney, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. 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. The party serving the request for production may move for an order compelling production under Rule 1.380. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. %%EOF 5. While "CID" is defined in Definition No. 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. 4. Fla. R. Civ. we will unquestionably offer. Even so construed, the request is duplicative, overbroad, and burdensome to the extent that it calls for documents already produced to Defendant in response to Defendant's February 2, 1999 Request for Documents, including, but not limited to, documents produced to Plaintiff by third parties, transcripts of the depositions of third parties, and correspondence from third parties to Plaintiff. Such documents include notes of Plaintiff's attorneys and staff and draft and final internal memoranda of Plaintiff, including, but not limited to, interview memoranda, status memoranda, and recommendation memoranda. 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. 125 0 obj <]/Info 118 0 R/Filter/FlateDecode/W[1 2 1]/Index[119 13]/DecodeParms<>/Size 132/Prev 24054/Type/XRef>>stream ), to whom the referenced Subpoena is directed, by and through his/her undersigned counsel, in accordance with Chapter 120, Florida Statutes, hereby files this Objection and Exceptions to DOH Subpoena No. 1) Overly broad 2) Unduly burdensome 3) Overly Costly 4) Repetitive or already in plaintiff's possession custody or control 5) Attorney-client privilege 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. Call the civil clerks office of your court to ask when Motion day is. Webflorida request for production of documents form. 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. 3. D. Ct. Local Rule 26.2 or pursuant to a Protective Order entered by the Court. 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. 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. Share sensitive information only on official, secure websites. Please produce any and all reports from any accident investigators or reconstruction experts or engineers. 131 0 obj <>stream All documents reflecting any statement of a third party to the DOJ and signed and/or adopted, formally or informally, by those third parties. 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. Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. Therefore, there are no "third part[ies]" as that term is defined. P. 1.350(b). Plaintiff further objects to this request as duplicative and burdensome to the extent that it calls for documents already produced to Defendant in response to Defendant's February 2, 1999 Request for Documents, including but not limited to transcripts of depositions of third parties and correspondence from third parties to Plaintiff. hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< WebAsk the judge to order the plaintiff to give you the documents you requested. The documents containing, including, or derived from "any verbatim statement of a third party" would include all documents created by Plaintiff in the course of the investigation preceding this case that touch explicitly or implicitly on any factual matter. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. Please produce any and all correspondence or similar communication between any parties to this action. Webc.) In addition to complying with the provisions of Rules. 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. 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 interrogatory to those individuals and entities interviewed by Plaintiff pursuant to Civil Investigative Demand Number 13009. 3. 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. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. 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. 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. While "CID" is defined in Definition No. Requests for production of documents and responses may be made on the record at depositions but usually should be confirmed in writing to avoid uncertainty. 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. A Rule 34 request can include a request to produce and permit the requesting party or its representative to inspect, copy, test, or sample the following items in the responding partys possession, custody, or control: > > Read More.. Time, Place and Manner of Inspection xbbd``b`J}@` Ll Ft? D 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. Requests for production are the means by which you can ask the other party to make copies of documents, photographs, records, etc., and to request the inspection of 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 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. 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] Requests for Admissions (RFAs) permit any party to request any other party to admit: (1) the truth of specified matters of fact, opinion relating to fact, or application of law to fact; or (2) the genuineness of specified documents. Plaintiff objects to Definition No. The information or documents Web requests for production of documents or to inspect any tangible thing; objections to requests for the production of documents or to inspect any tangible thing; written requests for admission; and answers or objections to written requests for admission; In that event, the interrogating party may ask the Court to review the propriety of the. 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 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). 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. 2. All such information, prepared in anticipation of litigation and not disclosed or otherwise maintained in a way that is inconsistent with the purpose of the privilege, is protected by the work product doctrine. It can be a long and tedious process, with much of it occurring outside of the courtroom. WebThe request is burdensome and oppressive. They can: IH55J6FL"B]Wsng@i! {.C6. motion to compel production of documents florida. 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. Fla. R. Civ. endstream endobj Plaintiff will make available for inspection at Plaintiff's offices responsive documents. PRODUCING DOCUMENTS OVER OBJECTION. WebObjections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. This document is available in two formats: this web page (for browsing content) and. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-000-0440, https://content.next.westlaw.com/practical-law/document/Ibd96133e8e9011e38578f7ccc38dcbee/Request-for-the-Production-of-Documents-RFP-FL?viewType=FullText&transitionType=Default&contextData=(sc.Default), Request for the Production of Documents (RFP) (FL). WebIn litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. we will unquestionably offer. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. 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. (NRCP 34; JCRCP 34.) Plaintiff objects to Definition No. WebIt is your agreed own times to action reviewing habit. Our goal is to help people in the best way possible. &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` _@@ If an objection is made only to part of a demand, the objectionable section must be specified. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. ORAL REQUESTS FOR PRODUCTION OF DOCUMENTS. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." 6. Webthe First Request for Production of Documents of Aurelius Capital Management, LP ("Aurelius"), to the Official Committee of Unsecured Creditors (the "Requests"), as 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. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. You and your lawyer will spend many hours on the process. 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. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiffs Complaint. While "CID" is defined in Definition No. 2. A specific response may repeat a general objection for emphasis or some other reason. WebPlaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly. If a party withholds otherwise discoverable information on the basis of privilege, that party must make this claim expressly and must describe the nature of the withheld materials such that, without revealing the disputed information, other parties may assess the applicability of the privilege. Plaintiff objects to each instruction, definition, document request, and interrogatory as overbroad and unduly burdensome to the extent it seeks documents or information that are readily or more accessible to Defendant from Defendant's own files, from documents or information in Defendant's possession, or from documents or information that Defendant previously produced to Plaintiff. Plaintiff objects to each definition, instruction, and document requests, 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. All documents reflecting any verbatim statement of a third party. The failure to include any general objection in any specific response does not waive any general objection to that request. Such a reading here demonstrates the problems with the use of this undefined term. 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. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. ih3S@k) \S D/)8?/,F{ lA0(s 8ibsc"! 8. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents and obtained other documents without issuance of a CID. Fla. R. Civ. 21. Secure .gov websites use HTTPS 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 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. Web35 requests that dont relate to the genuineness of documents by simply stating that the requesting party has exceeded the numerical limit. (a) Unless otherwise indicated, this Request for Documents concerns and relates to the incident which is described in Plaintiffs Complaint. P. 1.380(b)(2). Plaintiff further objects to Definition No. 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. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. [CCP 2033.010.] Documents already produced will not be produced again. See sample Request for Production of Documents. 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. Plaintiff objects to Instruction No. 8. Webregarding requests for production of documents. The request is irrelevant to the underlying nature of this proceeding. 3. Web4. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS DOCUMENT REQUEST NO. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. All expert reports from any experts who will testify at trial. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best If an objection is made only to part of a demand, the objectionable section must be specified. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. If an objection is made to part of an item or category, the part must be specified. To the extent any of Defendant's document requests seek documents that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests 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 to be determined by the Court. Plaintiff, by and through its attorneys, and pursuant to Rules 33 and 34 of the Federal Rules of Civil Procedure and the Local Rules of this Court, responds and objects to Defendant Dentsply International, Inc.'s ("Dentsply") Second Request for Documents and First Set of Interrogatories as follows: 1. 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). An attorney receiving a request for documents or a subpoena duces tecum shall reasonably and naturally interpret it, recognizing that the attorney serving it generally does not have specific knowledge of the documents sought and that the attorney receiving the request or subpoena generally has or can obtain pertinent knowledge from the client. Rule 12.351 - PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION (a) Request; Scope. 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 OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. (Code Civ. 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 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. READING AND INTERPRETING REQUESTS FOR DOCUMENTS. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. Plaintiff can only know those facts, of which it is aware, that are known to such individuals and entities. * Not Reasonably Particularized C.C.P. 3. All of the depositions taken of individuals listed in Plaintiff's Rule 26(a)(1) Initial Disclosures, all documents produced by the individuals and entities listed in these Disclosures, and all of the correspondence from such individuals and entities listed in such Disclosures have already been, or are being, produced to the Defendant. "During" can be construed to mean "at the time of," instead of "in the course of." 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. Request for Production in Florida Circuit Court At A Glance, Ex Parte Motion in United States District CourtAt A Glance, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. HW[O#7~1d. Judith M. Kinney (DSB # 3643) Assistant United States Attorney 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277, This document is available in two formats: this web page (for browsing content) and. 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 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. entities owning the property where the plaintiff was injured, as described in the Complaint. By making the accompanying responses and these objections to Defendant's requests for production, 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. Please produce any medical or employment records you have obtained relating to the Plaintiff. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. 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. 2 regarding "DOJ." 4 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. may be obtained only as Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth. As noted above, such a log would include virtually every internal document created by Plaintiff over the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. It is not not far off from the costs. P. 1.350(b). Use the following instructions to complete the Request for Production of Documents on page WebA 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. '' can be construed to mean `` at the time of the as... By the potential testifying expert economist similar communication between any parties to this request as vague and ambiguous it. Share sensitive information only on official, secure websites of Dentsply insurance policies in effect the... Maintained in a manner consistent with maintaining the protections afforded work product investigation... 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