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If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.
Post-judgment discovery typically consists of interrogatories and requests to produce. The interrogatories are questions designed to uncover any assets the debtor may possess or has recently possessed. The request to produce forces the debtor to produce specific documents in order to verify assets.
Use a Request for Production when you want the other side to produce documents and things as well as a statement under oath that they have provided the documents or things requested, or what they haven't produced and why.
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).
A request for production occurs when one party asks another to procure ESI or physical evidence. For example, this may include emails, photographs, text messages, charts, or graphs. On the other hand, physical evidence may encompass items like paper and gifted objects.
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...
Your response for each request must include either an agreement to comply, a representation of your ability to reply, or an objection to all or part of the request. California Code of Civil Procedure (CCP) §§ 2031.210 et. seq require specific statements in your response.
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.