2: All business licenses currently standing in your name or for any entity for At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 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. 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. 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. Webthose all. P. 1.350(b). P. 1.280(b)(5). Fla. R. Civ. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. 2. 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 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. 6. hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7<
OBJECTIONS. 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." 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 "third party" to those individuals and entities interviewed by Plaintiff pursuant to Civil Investigative Demand Number 13009. 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 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. USE OF FORM REQUESTS. Documents already produced will not be produced again. 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. Official websites use .gov To learn more about Request for Production of Documents and how to use them, visit www.MassLegalHelp.org and search Request for Production of Documents. When producing documents, the response must include an accompanying 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. If an objection is made to part of an item or category, the part shall be specified. 125 0 obj
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Moreover, Plaintiff does not waive its right to amend its responses. Call the civil clerks office of your court to ask when Motion day is. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). Furthermore, Civil Investigative Demand 13009 was issued to Dentsply, not to third parties. 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. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. 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. This objection encompasses, but is not limited to, documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant. Webthose all. Plaintiff objects to Definition No. 5. This document is available in two formats: this web page (for browsing content) and. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. is purposefully implementing that plan in good faith. WebThe request is burdensome and oppressive. 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. 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. Moreover, Plaintiff does not waive its right to amend its responses. %PDF-1.4
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Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. Its more or less what you craving currently. REQUEST NO. %PDF-1.5
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Here are the top five considerations when representing a non-party who receives a subpoena for production of documents. 5. 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. Thus, a request for production of document may be compound. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. 3. 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. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of the Antitrust Division. 3 to refer to "Civil Investigative Demand No. . (NRCP 34; JCRCP 34.) Creative Writing Apex Quiz Answers Psychology 12th Carole Wade 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 Therefore, there are no "statements" as that term is defined. 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 process can be very difficult, for all parties involved. 3. 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. 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. 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. 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. 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. 2. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. 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. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." With regard to the 184 individuals and entities who were interviewed by the DOJ pursuant to its CID investigation of Dentsply and subsequently identified in Plaintiff's Rule 26(a)(1) Initial Disclosures, please identify in detail all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter. REQUEST FOR PRODUCTION OF DOCUMENTS . 1, which also used this undefined term, Plaintiff used "contain, include, or are derived from" as the equivalent of "reflecting" in an attempt to read the request broadly. Civil Investigative Demand Number 13009 was not an investigation, it was a document request. WebAn objection that a discovery request is not relevant must include a specific explanation describing why the request lacks relevance and/or why the requested discovery is Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. Fla. R. Civ. 2 regarding "DOJ." WebFLORIDA RULE OF CIVIL PROCEDURE 1.380: The language of Fla. R. Civ. 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). Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. Discovery is a tedious process, both propounding discovery and answering discovery. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce all non-privileged, responsive documents obtained from third parties during its civil investigation of Dentsply's distribution and marketing of artificial teeth, with the exception that Plaintiff will withhold any documents or material that may contain confidential information until it receives direction from the Court regarding production pursuant to Local Rule 26.2 or a Protective Order has been entered by the Court allowing the production of that material. It is not not far off from the costs. Plaintiff, by and through its attorneys, and pursuant to Rule 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") Request for Documents as follows: 1. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." WebIt is your agreed own times to action reviewing habit. 5 regarding "third party" to the extent it relies on the undefined term "CID investigation." 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. D. Ct. Rule 26.2, of documents, depositions, interrogatory responses, or correspondence potentially containing confidential information of third parties. This Standard Document has integrated drafting notes with important explanations and drafting tips. All expert reports from any experts who will testify at trial. Sunny Balwani Sentenced Is This the Final Theranos Chapter. _ yuj
Specify the records to be produced in sufficient detail to permit the interrogating party to locate and identify the records and to ascertain the answer as readily as could the party from whom discovery is sought. 21. A party and counsel ordinarily have complied with the duty to respond to a document request if they have: Responded to the requests within the time set by the governing rule, stipulation, or court-ordered extension. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. 7. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." ORAL REQUESTS FOR PRODUCTION OF DOCUMENTS. endstream
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P. 1.380 applies to all discovery: depositions, admissions, responses to requests to produce, etc. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the 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. 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. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. P. 1.350(b). WebHere are a handful of those templated objections that could be used during an interrogatory which may be cause for documents to be protected from disclosure. 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. In addition to complying with the provisions of Rules. WebSample Objections To Request For Production Of uments that. 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. SUPPLEMENTATION OF DOCUMENT PRODUCTION. 310 or 1.320, or a corporati on or other entity fails to Alternatively, Plaintiff will produce copies of the documents. WebIt is your agreed own times to action reviewing habit. The authorities cited in this At A Glance Guide are current as of the publication date. Your response to this request should be periodically supplemented. (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. 1. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? Indeed, the Court has ordered the parties to disclose the likelihood that they will call those persons as witnesses, and Plaintiff has done so, reducing the list of 184 individuals and entities to 31 individuals whose testimony Plaintiff is very likely or likely to present at trial, either by live testimony or deposition. 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. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. 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. we will unquestionably offer. We meet the expense of Sample Objections To Request For Production Of uments and numerous books collections from fictions to scientific research in any way. 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). (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. 1: All documents reflecting any statement of a third party to 76 0 obj
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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 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. Objected with specificity to objectionable requests and included reasons. 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. 7. Furthermore, attorneys are reminded that evasive or incomplete disclosures, answers, or responses may be sanctionable under the provisions of. 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. Words used in discovery normally should carry their plain and ordinary meaning unless the particular case requires a special or technical definition, which should be specified plainly and concisely by the party required to respond to the term(s). A party objecting to a request for production must provide the reasons for the objection. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 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. WebObjection to SUBPOENA NO. 4. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). Please produce any medical or employment records you have obtained relating to the Plaintiff. Plaintiff further objects to this definition to the extent that it uses the undefined term "during." 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. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. 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 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. 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. All documents, papers or evidence to be introduced at trial. 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. 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. 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. endstream
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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. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 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 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. As used in this Request for Production of Documents, the following terms mean: The person(s) to whom this Request for Documents is addressed and all other persons acting or purporting to act on said persons behalf. WebREQUESTS FOR PRODUCTION 1. 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. Procedural Law v. Substantive Law What Is The Differance? 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