Illinois 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.

How to fill out Plaintiff's Response To Defendant's First Request For Production Of Documents - Personal Injury?

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FAQ

However, you can object to interrogatories that call for legal conclusions. You can also object to questions if they are not at all related to the court case. To object, you need to write out the reasons for the objection instead of answering the question.

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.

Pursuant to Supreme Court Rule 213, a motion for leave of court to serve more than thirty (30) interrogatories must be in writing and shall set forth the proposed interrogatories and the reasons establishing good cause for their use.

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.

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.?

A party has a duty to seasonably supplement or amend any prior answer or response whenever new or additional information subsequently becomes known to that party.

(g)Limitation on Testimony and Freedom to Cross-Examine. The information disclosed in answer to a Rule 213(f) interrogatory, or in a discovery deposition, limits the testimony that can be given by a witness on direct examination at trial.

The most important aspect of Rule 213 is the requirement that parties disclose the identity of any witnesses they plan to call at trial to provide expert testimony as well as a written report detailing the opinions and basis for those opinions of the witness.

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