WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. WebIt is your agreed own times to action reviewing habit. The producing party shall make available any computerized information or summaries that it either possesses or can produce by a reasonably efficient procedure. 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 material produced in response to Civil Investigative Demand Number 13009. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. 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. All documents, papers or evidence to be introduced at trial. Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident. Going through discovery is a bit like navigating a minefield. REQUEST NO. 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. P. 1.380(b)(2). Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the incident or any person or physical object which relate in any way to the circumstances of the incident. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. P. 1.350(b). d.) The Subpoena requests production of documents by RACHLIN of its working papers. 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. Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. Its more or less what you craving currently. 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. 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. 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. Specific objections should 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). OBJECTIONS. 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. The responsive material includes teeth, shade guides, a video tape and a CD-ROM.Alternatively, Plaintiff will produce copies of the documents, except the teeth, the shade guides, the videotape, and the CD-ROM, all of which will be available for inspection at Plaintiff's offices. > All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Neither should burdensome "boilerplate" definitions or instructions be used in formulating a document request or subpoena. 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. 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. 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. (Code Civ. Fla. R. Civ. Therefore, there are no "statements" as that term is defined. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 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. Share sensitive information only on official, secure websites. 21. 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. Requests for Production United States District Court Southern District of Florida. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). 7. we will unquestionably offer. 2. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 2 regarding "DOJ." D. Ct. Rule 26.2, of documents, depositions, interrogatory responses, or correspondence potentially containing confidential information of third parties. 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. 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 _ yuj The intent of the Rule is clear, stating, Discovery of facts known and opinions held by experts . Plaintiff objects to Definition No. 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). 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. The producing party either must produce the documents or items specified as they are kept in the regular course of business, or must identify them to correspond to the categories in the request. 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. 3 to refer to "Civil Investigative Demand No. A .gov website belongs to an official government organization in the United States. (a) Unless otherwise indicated, this Request for Documents concerns and relates to the incident which is described in Plaintiffs Complaint. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. Our goal is to help people in the best way possible. 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. All expert reports from any experts who will testify at trial. 3. 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. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. Plaintiff objects to Definition No. 3 to refer to "Civil Investigative Demand No. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. Procedural Law v. Substantive Law What Is The Differance? 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. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. Plaintiff will make available for inspection at Plaintiff's offices responsive documents. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 125 0 obj <]/Info 118 0 R/Filter/FlateDecode/W[1 2 1]/Index[119 13]/DecodeParms<>/Size 132/Prev 24054/Type/XRef>>stream Subject to and notwithstanding this objection, Plaintiff will use the more expansive definition of "third party" that it has provided in above Objection 3, and it will treat "statements" as covering those made by the individuals and entities listed in Plaintiff's Rule 26(a)(1) Initial Disclosures during Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. 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 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. 5 regarding "third party" to the extent it relies on the undefined term "CID investigation." Subject to and notwithstanding this objection, in responding to these discovery requests, Plaintiff will treat the term "third party," as extending to all individuals and entities, not named as parties to this lawsuit, listed on Plaintiff's Rule 26(a)(1) Initial Disclosures. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. %PDF-1.5 % Please keep this in mind if you use this service for this website. 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. Plaintiff objects to Definition No. xb```"7 Fm cjMf\ V5p 4,PpSOK #H3-W, "` f 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. For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in which event the reasons for the objection is made to part of an item or category, the part shall be specified. Fla. R. Civ. 3. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these Please produce any and all reports from any accident investigators or reconstruction experts or engineers. Share sensitive information only on official, secure websites. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than Creative Writing Apex Quiz Answers Psychology 12th Carole Wade Fla. R. Civ. 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. 2: All business licenses currently standing in your name or for any entity for You will likely be asked to provide a long list of answers and fetch a lot of documents. See sample Request for Production of Documents. All documents obtained by the DOJ pursuant to its CID investigation of Dentsply's distribution and marketing of artificial teeth. 5. 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. Secure .gov websites use HTTPS If a party objects to a request as overbroad when a narrower version of the request would not be objectionable, the documents responsive to the narrower version ordinarily should be produced without waiting for a resolution of the dispute over the scope of the request. READING AND INTERPRETING REQUESTS FOR DOCUMENTS. Because, however, all such transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth may contain confidential information, Plaintiff will withhold production of such transcripts 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. 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. 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. RFAs are a powerful trial-preparation tool. This Standard Document has integrated drafting notes with important explanations and drafting tips. 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 WebWith respect to each document produced, identify the person producing the document and the paragraph or subparagraph number of the request. 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. 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. See Objections 3-4 to Instructions and Definitions ("Objections 3-4"). 6. Plaintiff objects to Instruction No. Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. 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. 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. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. Objected with specificity to objectionable requests and included reasons. 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. Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. While "CID" is defined to refer to "Civil Investigative Demand No. Moreover, Plaintiff does not waive its right to amend its responses. Defendant's document requests call for the production of documents that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. 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. D. Ct. Rule 26.2, of potentially confidential materials produced to Plaintiff by third parties. P. 1.340 (b) an interrogatory otherwise proper is not objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or calls for a conclusion or asks for information not within the personal knowledge of the party. (Montanez v.
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