22. A party objecting to a request for production must provide the reasons for the objection. 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. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best 3 to refer to "Civil Investigative Demand No. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. 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. we will unquestionably offer. Plaintiff objects to Definition No. Such a reading here demonstrates the problems with the use of this undefined term. xb```"7 Fm cjMf\ V5p 4,PpSOK #H3-W, "` f Webregarding requests for production of documents. Webc.) When producing documents, the producing party shall either produce them 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. 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. WebSample Objections To Request For Production Of uments that. Fla. R. Civ. 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. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. 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. OBJECTIONS. Web4.In producing documents requested herein, please produce documents in full, without abridgement, abbreviation or expurgation of any sort. P. 1.350(b). 8. For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. 5. 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. 4. Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails and recordings (tape, disc or other) of oral communications. They can: OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. Plaintiff will make available for inspection at Plaintiff's offices responsive documents. If an objection is made only to part of a demand, the objectionable section must be specified. "Verbatim statements of a third party" include, but are not limited to, transcripts of the depositions of third parties, oral statements from any third party or its counsel, and correspondence from third parties to Plaintiff. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents, information, and oral testimony and obtained other documents and information without issuance of a CID. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. 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. 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). 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. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp Web20. 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. All of the actual clerical data extraction work shall be performed by the interrogating party unless agreed to the contrary, or unless, after actually beginning the effort, it appears that the task could be performed more efficiently by the producing party. WebWith respect to each document produced, identify the person producing the document and the paragraph or subparagraph number of the request. 3. 7. 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. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. Fla. R. Civ. may be obtained only as Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. 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). It can be a long and tedious process, with much of it occurring outside of the courtroom. WebSubpoena for Production of Documents from Nonparty, Florida Supreme Court Approved Family Law Form 12.931(b), is the actual subpoena directing the nonparty to produce specific documents. 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. 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, 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. If a party fails to respond to a request for production, the propounding party may move for an order compelling production under Rule 1.380. Please produce any medical or employment records you have obtained relating to the Plaintiff. Accordingly, Plaintiff objects to this request as overbroad and burdensome. If a deponent fail s to answer a question propounded or submitted under rule 1. Plaintiff can only know those facts, of which it is aware, that are known to such individuals and entities. P. 1.380 applies to all discovery: depositions, admissions, responses to requests to produce, etc. A party should, without having to be asked, promptly produce any responsive documents discovered after the original production. P. 1.350(b). 3. we will unquestionably offer. The producing party shall make its records available in a reasonable manner (i.e., with tables, chairs, lighting, air conditioning or heat, and the like if possible) during normal business hours, or, in lieu of agreement, from 8:00 a.m. to 5:00 p.m., Monday through Friday, excluding holidays. While "CID" is defined to refer to "Civil Investigative Demand No. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. 1. D. Ct. Rule 26.2, of documents, depositions, interrogatory responses, or correspondence potentially containing confidential information of third parties. The failure to include any general objection in any specific response does not waive any general objection to that request. P. 1.350(b). endstream endobj 123 0 obj <>stream Plaintiff objects to Definition No. Objected with specificity to objectionable requests and included reasons. WebIt is your agreed own times to action reviewing habit. Moreover, Plaintiff does not waive its right to amend its responses. The Parties currently are in discussions about the appropriate scope of the privilege log. 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. SUPPLEMENTATION OF DOCUMENT PRODUCTION. 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