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District of Columbia Plaintiff's Response to Defendant's First Request for Production of Documents - Personal injury

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US-PI-0191
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This form is a sample plaintiff's response to the defendant's first request for the production of certain documents in a personal injury action.

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FAQ

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.

Check or type: ?I will allow this request in whole and will provide the documents or things as requested.? Check or type: "I cannot comply with the request because no such documents or things exist. A diligent search and reasonable inquiry have been made in an attempt to comply with this demand.?

If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.

There should be only three goals in answering interrogatories: accurate, complete, minimal. Accuracy is important because, pursuant to Rule 33(a), SCRCP, these answers are verified by the client under oath and, under Rule 801(d)(2), SCRE, are admissions of a party opponent.

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.

Answer. Requests for the Production of Documents. 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.

You have 30 days to respond to the interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond. Just below the top caption identifying the case, the form identifies the Answering (or Responding) party. Make sure that this is you.

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.

More info

Sample requests for production of documents in personal injury cases. Free example RPDs for car accident, medical malpractice, and other personal injury ... Mar 22, 1999 — Plaintiff's Responses And Objections To Defendant's Second Request for Documents and First Set Of Interrogatories. Share right caret.Below is a sample request for production of documents in a motor vehicle crash case that later settled for $750,000. This is a general first set request for ... The most common forms of discovery are written, and are interrogatories as well as requests for production of documents, and each are afforded the same weight. Mar 22, 1999 — 3. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. Dec 11, 2020 — Requests for the production of documents are a written tool used in the initial written discovery phase of most personal injury lawsuits. HOW TO RESPOND TO REQUESTS FOR PRODUCTION OF DOCUMENTS. • Requests for Production of Documents are a list of documents you must allow the other party or their ... The First Set of Requests for Production of Documents. (each a “Request for Production,” and collectively “Requests for Production”) seeks production of all ... Jun 20, 2023 — more specific with respect to the documents the plaintiff seeks. Defendants will file a reply in response to Plaintiff's opposition motion. First, the plaintiff can request a default judgment from the Clerk by filing an affidavit or declaration (which are discussed on page 12 of this handbook) ...

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District of Columbia Plaintiff's Response to Defendant's First Request for Production of Documents - Personal injury