7. 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. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. 4. While "CID" is defined in Definition No. 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. 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. Official websites use .gov 1. 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. entities owning the property where the plaintiff was injured, as described in the Complaint. 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. Fla. R. Civ. production of documents shielded from discovery based on work product immunity, attorney-client privilege and other applicable privileges and immunities. IH55J6FL"B]Wsng@i! {.C6. 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. WebObjections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. 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. A specific response may repeat a general objection for emphasis or some other reason. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. The Parties currently are in discussions about the appropriate scope of the privilege log. 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. 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. Webthe First Request for Production of Documents of Aurelius Capital Management, LP ("Aurelius"), to the Official Committee of Unsecured Creditors (the "Requests"), as ), 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. 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. 1. Nor have such notes and/or memoranda of interviews been seen by anyone other than the case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. While "CID" is defined to refer to "Civil Investigative Demand No. Such materials contain the mental impressions, conclusions, opinions, and legal theories of the Government's attorneys in summarizing the Government's understanding of information obtained in the interview, for instance by the emphasis in memoranda of the specific issues of interest to the Division's legal analysis. Plaintiff objects to Instruction No. 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." Consequently, there are no individuals and entities who were interviewed by the DOJ pursuant to its "CID" investigation of Dentsply. Plaintiff objects to Instruction No. 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. ORAL REQUESTS FOR PRODUCTION OF DOCUMENTS. A 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. Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. Timing. Procedural Law v. Substantive Law What Is The Differance? 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. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. Its more or less what you craving currently. 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 Instruction No. Here are the top five considerations when representing a non-party who receives a subpoena for production of documents. Please produce any and all reports from any accident investigators or reconstruction experts or engineers. Plaintiff can only know those facts, of which it is aware, that are known to such individuals and entities. Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. All such documents will not be produced. 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. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. P. 1.350(b). All expert reports from any experts who will testify at trial. 3 to refer to "Civil Investigative Demand No. If an objection is made to part of an item or category, the part must be specified. 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. Fla. R. Civ. 7. 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. 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. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. 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. %PDF-1.4 % endstream endobj 63 0 obj <>stream WebUnder, Fla. R. Civ. 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. 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. . 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. It can be a long and tedious process, with much of it occurring outside of the courtroom. 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. WebThe request is burdensome and oppressive. 4. Web Produce documents, information, or objects, or to permit inspection of premises, is the AO 088B. All documents obtained by the DOJ pursuant to its CID investigation of Dentsply's distribution and marketing of artificial teeth. Providing such information in answering this interrogatory would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of providing such information in answering this interrogatory is substantially the same or less for Defendant as for Plaintiff. The party serving the request for production may move for an order compelling production under Rule 1.380. P. 1.350 (b) (amended eff 10/28/21). During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents and oral testimony and obtained other documents without issuance of a CID. REQUEST NO. 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. 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). 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. Such a reading here demonstrates the problems with the use of this undefined term. Plaintiff objects to Definition No. 5. 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. 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. 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 request to the extent that it calls for documents readily or more accessible to Defendant from Defendant's own files, including without limitation documents produced by the Defendant to Plaintiff. WebObjection to SUBPOENA NO. 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. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. 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. 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). Web4. * Not Reasonably Particularized C.C.P. 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] 3 to refer to "Civil Investigative Demand No. WebSample Objections To Request For Production Of uments that. 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. 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. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 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. 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. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. 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. 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. Plaintiff objects to Definition No. 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. . Compliance with Request. hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< 2 regarding "DOJ." 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. 1. 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. 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. Include all documents and 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. 5. Ensured a reasonable inquiry with those persons and a reasonable search of those places likely to result in the discovery of responsive documents. Stated whether any responsive materials are being withheld on the basis of an objection. Webthose all. 21. 6. 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. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." WebREQUESTS FOR PRODUCTION 1. 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. 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. respond to Defendants Sam and Edith Rosens First Request for Production upon Plaintiffs as follows: SPECIFIC OBJECTIONS AND RESPONSES 1. This request, in essence, then, asks for the recollections of the attorneys representing the United States, or of the staff working under their direction, or for information contained in memoranda and notes prepared by those attorneys and their staff. 89 0 obj <>stream These interviews were conducted by attorneys and staff of Plaintiff. 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 hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ While "CID" is defined in Definition No. P. 1.350(b). Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." P. 1.280(b)(5). 4. 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 This disclosure will allow Defendant to identify those individuals from whom it needs detailed information. Webregarding requests for production of documents. Documents already produced will not be produced again. &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` _@@ 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. Any and all land records, contracts, documents or the like reflecting the persons or. Alternatively, Plaintiff will produce copies of the documents. 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. > 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 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. WebPlaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly. Please keep this in mind if you use this service for this website. Plaintiff will make available for inspection at Plaintiff's offices responsive documents and things. 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. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. All documents reflecting any verbatim statement of a third party. 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 further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." 2: All business licenses currently standing in your name or for any entity for Plaintiff will make available for inspection at Plaintiff's offices responsive documents. 5. WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. Fla. R. Civ. 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. 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. 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 That person shall be one who is fully familiar with the records system and, if a question concerning the records arises and the designated person cannot answer, the producing party should act reasonably and cooperatively in locating someone who knows the answer to the question. if the request just reads, Produce the documents you showed me, the request would be vague or ambiguous, since you might have shown the requesting party Discovery is a tedious process, both propounding discovery and answering discovery. 3 to refer to "Civil Investigative Demand No. 3. Accordingly, Plaintiff objects to this request as overbroad and burdensome. WebIn litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. 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. among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. 0 Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. If an objection is made to part of an item or category, the part shall be specified. As a practical matter, many attorneys produce or exchange documents upon informal request, often confirmed by letter. 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 For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. 119 0 obj <> endobj [CCP 2033.010.] 3 to refer to "Civil Investigative Demand No. Fla. R. Civ. All such documents and information will not be produced. Plaintiff will construe "during" to mean "in the course of.". Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. Thus, a request for production of document may be compound. While "CID" is defined to refer to "Civil Investigative Demand No. Neither should burdensome "boilerplate" definitions or instructions be used in formulating a document request or subpoena. An official website of the United States government. When producing documents, the response must include an accompanying A .gov website belongs to an official government organization in the United States. 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. When production is limited by a party's objection, the producing party should clearly describe the limitation in its response. 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. 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). Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. 2 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. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. `` CID '' is defined to refer to `` Civil Investigative Demand No in! 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