[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Address] [City, State, ZIP] Subject: Response to Request for Production of Documents Dear [Recipient's Name], I hope this letter finds you well. I am writing in response to your request for the production of documents dated [date of the request], pursuant to [mention the specific court rule or statute governing discovery]. As per your request, I have compiled the necessary documents for your review and am I providing detailed responses as follows: 1. Identification of Documents: In accordance with your request, I have attached an itemized list of the documents being produced. Each document is described and numbered accordingly for ease of reference. If any documents are being withheld or are otherwise protected under applicable privileges, I have made appropriate notes to that effect. 2. Format of Production: The documents will be provided electronically in PDF format via secure file-sharing platforms or on a disk, depending on your preferred method of delivery. Please specify your preference, and I will ensure that the documents are delivered accordingly. 3. Objections: I must note that, although I have made every effort to comply fully with your request, there are certain objections raised in accordance with the applicable rules of discovery. These objections are specifically based on [mention relevant grounds such as privilege, relevance, scope, proportionality, etc.]. I have listed these objections in a separate document accompanying this response for your convenience. 4. Privilege Logs: If any documents are being withheld based on privilege, I will provide a privilege log detailing the nature of the withheld documents, including their date, author, recipients, subject, and the specific privilege being claimed. 5. Document Organization: To facilitate your review, the produced documents will be organized in a logical and coherent manner. I will include an index or table of contents outlining the categories or topics covered by the documents provided. Should you have any questions or further requests regarding this response, please do not hesitate to contact me directly. I will make every effort to address any concerns promptly and ensure a smooth exchange of documents. Please note that this production is made without waiving any objections or privileges, and it does not constitute an admission or agreement regarding the authenticity or admissibility of any document or information contained therein. Thank you for your attention to this matter. I appreciate your cooperation in the discovery process, and I look forward to a productive and efficient resolution of this case. Yours sincerely, [Your Name]
Colorado Sample Letter for conveying Responses to Request for Production of Documents
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How to fill out Colorado Sample Letter For Conveying Responses To Request For Production Of Documents?
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Discovery: Responding to Requests for Production or Inspection Complete Your Written Responses. Objections. Make Copies. Have Your Response Served. Retain Your Response and Proof of Service. Produce the Requested Documents and Things.
Section 3. (b) As a general rule, within 35 days after you are served with these requests for production of documents, you must serve your responses on the asking party and serve copies of your responses on all other parties to the action who have appeared. See C.R.C.P. 34 for details.
For example, if the other party asks you to produce ?any and all records from your bank account,? you may want to object, as this request is overly broad, and it is unduly burdensome for you to locate and produce every document you have ever received from your bank since you opened the account.
A party may file a motion to compel with permission of the Court when the other party unreasonably fails to make disclosures or has been evasive or filed incomplete answers. Permission to file a Motion To Compel may be requested at a status conference. Conferral with the opposing party must occur before a request.
Your response must be given under oath and should include the following language at the end of the document, above a line with the date and your signature: ?I declare under penalty of perjury under the laws of the State of California that the forgoing answers are true and correct.?
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).
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.
Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit.
