Connecticut Sample Letter containing additional Responses or Clarifications to Requests for Production of Documents

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Multi-State
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US-0156LTR
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This form is a sample letter in Word format covering the subject matter of the title of the form.

[Your Name] [Your Address] [City, State ZIP Code] [Email Address] [Phone Number] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State ZIP Code] Re: Additional Responses and Clarifications to Requests for Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. I am writing in response to your Requests for Production of Documents served on [Date], as part of the ongoing litigation between our clients. As previously indicated, and to ensure compliance with the discovery process, I have provided additional responses and clarifications to the specific requests outlined in your document production demands. 1. Request [Insert Request Number] Description: [Briefly describe the specific request in question] Response: [Provide a detailed response regarding the availability, status, and significance of the requested documents. If any documents are being withheld on grounds of privilege or other legal objections, clearly state the reasons for such actions.] 2. Request [Insert Request Number] Description: [Briefly describe the specific request in question] Response: [Provide a detailed response regarding the availability, status, and significance of the requested documents. If any documents are being withheld on grounds of privilege or other legal objections, clearly state the reasons for such actions.] 3. [Repeat the above pattern for each request, if applicable] Additionally, I would like to request the following clarifications related to your document production demands: 1. Clarification Request [Insert Clarification Request Number] Description: [Specify the request or section of the requests that require further clarification] Clarification: [Clearly explain the ambiguity or vagueness in the original request, and seek clarification to ensure accurate production of responsive documents.] 2. [Repeat the above pattern for each clarification request, if necessary] Please note that the aforementioned responses and clarifications are being provided without waiving any objections, including, but not limited to objections based on privilege, relevance, burdensomeness, scope, or any other applicable grounds under the relevant rules of civil procedure. In compliance with our obligations under the discovery process, I am concurrently producing a set of corresponding documents, organized in a manner consistent with your requests. The documents will be provided to you either electronically or in hard copy format, based on your preference. Please confirm your preferred format and the appropriate address where the documents should be sent. Should you have any questions or require further clarification, please do not hesitate to contact me at [Phone Number] or via email at [Email Address]. I would be more than happy to discuss any concerns you may have regarding the document production process or assist in resolving any outstanding issues to facilitate the smooth progress of our litigation. Thank you for your attention to this matter. I look forward to hearing from you soon. Sincerely, [Your Name]

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(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).

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).

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.

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.

Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.

How to Request Production of Documents and Things Download the template for Request for Production. ... Fill out basic information at the top. ... Choose a location for the other side to bring the documents. ... Add your own definitions (if useful) ... Write your requests for production. ... Sign and date the document. ... Make copies.

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.

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Connecticut Sample Letter containing additional Responses or Clarifications to Requests for Production of Documents