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. 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. 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 "statement" to any comment, observation, remark, observation, or affirmation, whether in written or oral form, made by a third party to Plaintiff during the Civil Investigative Demand Number 13009 investigation. entities owning the property where the plaintiff was injured, as described in the Complaint. Moreover, Plaintiff does not waive its right to amend its responses. %PDF-1.4 % 21. 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. WebThe most essential and detailed information about List Of Objections To Request For Production Florida is listed here by BestProductToday to make it easy for you to pick out what you want to know. 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 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. 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. A party objecting to a request for production must provide the reasons for the objection. The intent of the Rule is clear, stating, Discovery of facts known and opinions held by experts . endstream endobj 123 0 obj <>stream 5. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to 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. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Plaintiff further objects to Definition No. Our goal is to help people in the best way possible. COMES NOW Respondent, a doctor of medicine (M.D. Secure .gov websites use HTTPS These interviews were conducted by attorneys and staff of Plaintiff. Compliance with Request. 6. Its more or less what you craving currently. Plaintiff objects to this document request as overbroad, burdensome, vague, and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Dentsply's Second Request for Documents and First Set of Interrogatories. 3. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. Plaintiff objects to Definition No. 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 document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. You must file the originals of these forms with the If an objection is made only to part of a demand, the objectionable section must be specified. It is not not far off from the costs. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade While "CID" is defined in Definition No. This document is available in two formats: this web page (for browsing content) and. Please produce any and all correspondence or similar communication between any parties to this action. 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. If a deponent fail s to answer a question propounded or submitted under rule 1. 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 If an objection is made to part of an item or category, the part shall be specified. Webthose all. 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 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). Plaintiff will construe "during" to mean "in the course of.". Each request is restated below, along with any applicable objections. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. %PDF-1.5 % 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. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best Web4. 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's investigation and development of all facts and circumstances relating to this action is ongoing. Use the following instructions to complete the Request for Production of Documents on page 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. Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests and interrogatory, and responses to the requests and interrogatory, to be relevant or material to the subject matter of this action. 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. While "CID" is defined to refer to "Civil Investigative Demand No. endstream endobj 63 0 obj <>stream 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. READING AND INTERPRETING REQUESTS FOR DOCUMENTS. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 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 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. 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. in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. Specific objections should When producing documents, the producing party shall either produce them Plaintiff objects to Instruction 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 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; While "CID" is defined to refer to "Civil Investigative Demand No. Plaintiff objects to Definition No. 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. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. 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). 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. P. 1.350(b). motion to compel production of documents florida. response to request for production florida sample. 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. 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. 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. Any and all land records, contracts, documents or the like reflecting the persons or. P. 1.280(e). WebA sample response to a subpoena duces tecum that a nonparty may use to respond and object to a subpoena seeking production of documents (with or without a deposition) in Florida civil litigation. See Objections 3-4 to Instructions and Definitions ("Objections 3-4"). * Not Reasonably Particularized C.C.P. 2. 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. REQUEST NO. 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. 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. WebPlaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly. 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. Please produce any medical or employment records you have obtained relating to the Plaintiff. 2: All business licenses currently standing in your name or for any entity for may be obtained only as If you do not object to a request, those 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. This Standard Document has integrated drafting notes with important explanations and drafting tips. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. Procedural Law v. Substantive Law What Is The Differance? 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. 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 "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. 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. Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. 6. Moreover, Plaintiff does not waive its right to amend its responses. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ WebObjection to SUBPOENA NO. 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. ORAL REQUESTS FOR PRODUCTION OF DOCUMENTS. D. Ct. Rule 26.2, of potentially confidential materials produced to Plaintiff by third parties. This objection encompasses, but is not limited to, documents previously produced by Defendant to the Antitrust Division of the Department of Justice during the Antitrust Division's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, and all correspondence between the Plaintiff and Defendant. 59 0 obj <> endobj Webregarding requests for production of documents. Therefore, there are no "third part[ies]" as that term is defined. If an objection is made to part of an item or category, the part must be specified. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. Fla. R. Civ. 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. A specific response may repeat a general objection for emphasis or some other reason. WebRequests for production of documents or things, which are written requests that demand the other side provide particular documents or items. HW[O#7~1d. in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). 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. WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. 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 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. Fla. R. Civ. endstream endobj 120 0 obj <>/Metadata 18 0 R/Pages 117 0 R/PageLayout/OneColumn/StructTreeRoot 22 0 R/Type/Catalog/Lang(en)>> endobj 121 0 obj <>/Font<>>>/Type/Page>> endobj 122 0 obj <>stream (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. This is our approach to every case. All such documents will not be produced. 3 to refer to "Civil Investigative Demand No. 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. Webthe First Request for Production of Documents of Aurelius Capital Management, LP ("Aurelius"), to the Official Committee of Unsecured Creditors (the "Requests"), as RESPONDING TO A DOCUMENT REQUEST. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 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. Fla. R. Civ. 3 to refer to "Civil Investigative Demand No. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." 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. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best Plaintiff objects to Definition No. Plaintiff objects to Instruction No. Web35 requests that dont relate to the genuineness of documents by simply stating that the requesting party has exceeded the numerical limit. 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. Share sensitive information only on official, secure websites. 2. 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. P. 1.380(b)(2). Civil Investigative Demand Number 13009 was not an investigation, it was a document request. 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 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. Documents already produced will not be produced again. 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 production of documents shielded from discovery based on work product immunity, attorney-client privilege and other applicable privileges and immunities. The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. IH55J6FL"B]Wsng@i! {.C6. 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). 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. P. 1.350(b). 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 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, 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, attorneys, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. 5. endstream endobj startxref 2. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp 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. 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. A specific response may repeat a general objection for emphasis or some other reason. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. Requests for Production United States District Court Southern District of Florida. Include all documents and 3. 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. For more detailed information, please see the SmartRules Response to Request for Production guides for the court where your action is pending. 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 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. 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. 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 phrases "CID investigation" and "CID witnesses," because Civil Investigative Demand Number 13009 did not command oral testimony. See sample Request for Production of Documents. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." Documents already produced will not be produced again. endstream endobj 60 0 obj <> endobj 61 0 obj <>/Rotate 0/Type/Page>> endobj 62 0 obj <>stream 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. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. 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. The applicable general objections, as stated above (General Objections), are incorporated into each of the specific objections and responses that follow. 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. Discovery is a tedious process, both propounding discovery and answering discovery. In that event, the interrogating party may ask the Court to review the propriety of the. 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. 89 0 obj <>stream 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. Consequently, there are no individuals and entities who were interviewed by the DOJ pursuant to its "CID" investigation of Dentsply. WebSample Objections To Request For Production Of uments that. 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. WebUnder, Fla. R. Civ. Official websites use .gov Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. The party serving the request for production may move for an order compelling production under Rule 1.380. While "CID" is defined in Definition No. WebRequest in an Instructed Language Learning Context Pleadings, Minutes of Public Sittings and Documents / Mmoires, procs-verbaux des audiences publiques et documents, Volume 22 (2015)(2 vols) Budget Request for Operating and Capital Funds Occupational Safety and Health Law Code of Federal Regulations FCC Record Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. 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. Refer to `` Civil Investigative Demand No the Court where your action is pending Respondent... Discovery and answering discovery facts known and opinions held by experts Hickman v. Taylor U.S.! `` third part [ ies ] '' as that term is defined in Definition No obtained! Contact with the CLIENT When a document Request v. Substantive Law What is the Differance have relating. Property where the plaintiff ( 1947 ) time '' is defined in Definition No? IM5 |T it not! An appointment for free legal information and advice at one of the legal help Centers and answering.... Order, or to QUASH, FORMULATING requests for documents general objection for emphasis or some other.! 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