[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: Responses to Request for Production of Documents — Your Case Name Dear [Opposing Party's Name], I hope this letter finds you well. As we have previously discussed, this letter serves as my formal response to your Request for Production of Documents dated [date] pursuant to Kentucky Rule of Civil Procedure [Rule Number]. Please consider this letter as my complete and substantial response to the aforementioned request. Upon careful review and consideration of your document requests, I have gathered and attached the relevant documents as requested. To ensure clarity and organization, I will address each specific document request separately. [List each document request number and its corresponding response paragraph here] 1. [Document Request Number 1]: [Provide a detailed description of the provided documents that fulfill this request. Include any relevant keywords related to the documents, such as contracts, invoices, financial records, etc.] 2. [Document Request Number 2]: [Describe the documents being supplied here, incorporating relevant keywords associated with the requested documents. For example, if the request pertains to medical records, use terms like medical reports, lab results, X-rays, etc.] Please note that the attached documents are being produced in their existing form and based on my reasonable and diligent search efforts. Any objections, limitations, or restrictions to the production of these documents are expressly waived for the purposes of this response. Additionally, no document listed shall be considered as an admission of authenticity or relevance for the purposes of this litigation. In the event that certain documents are not included due to privilege, their absence should not be construed as an admission that they exist or are being withheld. If additional documentation is discovered or becomes available, I will promptly provide it to you to ensure transparency. Finally, pursuant to Kentucky Rule of Civil Procedure [Rule Number], I request that you reciprocate by producing all responsive documents within the specified time frame. In the event that you are unable to comply fully with any request, I expect a complete written explanation as to why, including any objections raised. Thank you for your attention to this matter. Should you require any further clarification or have any concerns, please do not hesitate to contact me at the provided phone number or email address. Yours sincerely, [Your Name]
Kentucky Sample Letter for conveying Responses to Request for Production of Documents
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FAQ
The most common discovery objection our lawyers see is the objection that the interrogatories are not relevant to the litigation or are too burdensome to answer. Another objection our attorneys see frequently because we asked detailed questions that pin down defendants is that the request calls for a legal conclusion.
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.
Stand up and face the judge. Don't give in to the temptation to face the opposing attorney who is making the objection. State your responses succinctly, being as specific as possible about the legal grounds for admissibility. Give a one-sentence non-legal explanation for the benefit of the jury.
Your response for each request must include either an agreement to comply, a representation of your ability to reply, or an objection to all or part of the request. California Code of Civil Procedure (CCP) §§ 2031.210 et. seq require specific statements in your response.
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.
"a blanket objection" is a correct and usable phrase in written English. It is typically used in informal contexts to describe a general disapproval or refusal of something. For example, "My boss has a blanket objection to anyone working from home.".
When you receive a Request for Production, the other side is asking you to hand over a document or item, usually to be copied. Sometimes, this is called a Demand for Inspection. You have 30 days to respond to a Request for Production.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
