California Responses To Defendant's First Request For Production To Plaintiff
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FAQ
I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
They are provided for your information. There is no form for your answer, but you typically have to respond in a specified format, using paper with numbers down the left-hand side, with your name and address at the top left, the name of the court and of the case, and the case number.
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you can't comply.
Requests for admission are used to ask another party to admit that certain facts are true, or that certain documents are authentic. If admitted as true or authentic, these facts and documents do not need to be proven or authenticated at trial.
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you can't comply.
CCP §§ 2031.210-2031.240. If all of the RFPs are not produced based solely on legal objections, the requests for production do not need to be verified. CCP § 2031.250. A party can not avoid complying based on burdensome objections.
(CCP § 2031.240). Unless your written response includes only objections without any factual assertions, it must be verified. This means it must include a statement under the penalty of perjury that your response is true and correct. (CCP § 2031.250).
For Federal Court, you want to look at the Federal Rules of Civil Procedure, particularly rules 33 and 34. Doc requests don't require verifications, and you serve only objections, you don't need verifications for interrogatory responses.
