Subject: Additional Responses and Clarifications to Requests for Production of Documents — North Carolina Dear [Recipient's Name], I hope this letter finds you well. I am writing in response to your requests for production of documents in relation to [case name or number]. In compliance with the rules of discovery, and as per your previous request, please find below our additional responses and clarifications: 1. Request for Production No. [X]: — Documents: We have attached copies of all relevant documents as requested, including [list specific documents]. — Privilege Log: Along with the production of documents mentioned above, we provide you with a separate privilege log that outlines any documents withheld on the grounds of attorney-client privilege or work product doctrine. — Format: All documents have been produced electronically in PDF format, clearly labeled and organized in a searchable manner. 2. Request for Production No. [Y]: — Documents: We hereby produce all documents in our possession, custody, and control as requested in your previous correspondence. These include [list specific documents]. — Redactions: To protect privileged information or any personal data of third parties, we have made certain redactions where appropriate. A privilege log accompanies this response. — Format: The documents have been provided in both hard copy and electronic formats, as requested. 3. Request for Production No. [Z]: — Documents: In response to this request, we acknowledge that no documents exist within our possession, custody, or control that are responsive to your query. — Affidavit of Nonexistence: To further confirm the nonexistence of any requested documents, we have attached an Affidavit of Nonexistence, duly sworn by an authorized representative of [your organization name]. — Basis for Nonexistence: We explain herein the reasons for nonexistence, clearly outlining any relevant documents that were destroyed or are beyond our control. Please note that all produced documents or information should be considered subject to applicable privileges or protective orders. If, upon review, you find any issues with the produced documents or require further clarifications, we are available for discussion and resolution. We kindly request that you confirm receipt of this letter and the attached documents. Furthermore, we anticipate receiving any supplemental responses or amended requests from your end, should any arise, so that we can ensure timely compliance. Thank you for your attention to this matter. We look forward to resolving any outstanding discovery issues and reaching a fair resolution to the case. Sincerely, [Your Name] [Your Title] [Your Organization] Keywords: North Carolina, sample letter, additional responses, clarifications, requests for production of documents, privilege log, format, redactions, affidavit of nonexistence, nonexistence, basis for nonexistence, discovery, fair resolution.
North Carolina Sample Letter containing additional Responses or Clarifications to Requests for Production of Documents
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How to fill out North Carolina Sample Letter Containing Additional Responses Or Clarifications To Requests For Production Of Documents?
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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).
(e) If a party then fails to obey an order compelling further response to requests for admission, the court may order that the matters involved in the requests be deemed admitted. In lieu of or in addition to this order, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010).
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.
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.
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.
If the fact that is stated is true, write or check the word ?Admit.? If the fact that is stated is not true, write or check the word ?Deny.?
Your response must be given under oath and should include the following language at the end of the document, above a line with the date and your signature: ?I declare under penalty of perjury under the laws of the State of California that the forgoing answers are true and correct.?
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.
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.
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.