[Your Name] [Your Address] [City, State, ZIP Code] [Email Address] [Phone Number] [Date] [Recipient's Name] [Recipient's Position] [Name of Organization] [Address] [City, State, ZIP Code] Subject: Response to Requests for Production of Documents — [Case Name/Number] Dear [Recipient's Name], I hope this letter finds you well. I am writing in response to the Requests for Production of Documents received from [Opposing Party/Attorney] on [Date]. As the designated custodian of records for [Your Organization], I am providing the following additional responses and clarifications to the requests outlined in their letter. [If there are different types of Idaho Sample Letter containing additional Responses or Clarifications to Requests for Production of Documents, name them here. For example:] 1. General Documents Request: The Opposing Party's Requests for Production of Documents broadly seek all documents related to [specific subject or timeframe]. In response to this request, we acknowledge our obligation to provide relevant documents under the applicable discovery rules. However, due to the broad nature of this request, we request additional clarification as to the specific categories or types of documents sought by the Opposing Party. 2. Documents with Confidentiality Concerns: In regard to the Requests for Production of Documents that involve sensitive or confidential information, we request that appropriate confidentiality designations be agreed upon and utilized to protect the privileged or proprietary nature of these documents. This will ensure that the information is appropriately safeguarded while still complying with the discovery process. 3. Electronically Stored Information (ESI): The Opposing Party's Requests for Production of Documents also include a demand for electronically stored information (ESI). We will cooperate in producing ESI to the extent feasible and within the scope defined by the applicable rules. However, we request clarification regarding the specific file types, sources, custodians, and relevant timeframes to ensure the efficiency and accuracy of the production process. 4. Document Production Timeline: We acknowledge our duty to complete the production of responsive documents in a timely manner. We propose the following schedule to efficiently handle this discovery request: — Within [number of days] from the date of this letter, we will provide a privilege log identifying any documents withheld on the basis of privilege or work product protection. — Within [number of days] from the receipt of the clarified requests, we will review and produce all non-privileged responsive documents in our possession, custody, or control. — Should additional time be required due to the volume or complexity of the documents, we will promptly notify you and seek agreement on an extended timeline. Please note that our responses are provided without waiving any objections or privileges. If you have any concerns or need further information, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your attention to this matter. We look forward to working with you to resolve this discovery dispute in an efficient and cooperative manner. Sincerely, [Your Name] [Your Title] [Your Organization]
Idaho Sample Letter containing additional Responses or Clarifications to Requests for Production of Documents
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How to fill out Idaho Sample Letter Containing Additional Responses Or Clarifications To Requests For Production Of Documents?
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FAQ
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.
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).
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.
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.
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.
(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).
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.