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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.
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.
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.
Prepare the template for your responses Whether on a form or not, the Request for Production will have a numbered list of documents or items they want you to produce. Make a list in the template. For each item, write ?Response to Request for Production Number? followed by the number of the request.
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.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.