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Requests to Produce ask a party for documents or categories of documents. Document requests include ESI such as electronic documents and data.Interrogatories, requests for production, requests for admission, and responses thereto shall be in writing and served on the other party. Throughout this request:. Each request herein demands PAPER documents and records as well as. Response: Objection. If you do not know or cannot ascertain the answer to any interrogatory, state that affirmatively in lieu of your answer. One common objection is that the request is to "burdensome". For example, the plaintiff is requesting 10 years of all your financial records. Before you start Form Interrogatories are a list of questions on a court form.