North Carolina 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

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.?

Rule 26 requires parties to keep their discovery requests reasonable and proportional to the matter at hand. Hence if you reduce the scope of discovery, you can drastically reduce its burden.

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.

Rule 27. Depositions before action or pending appeal. (1) Petition. ? A person who desires to perpetuate his own testimony or that of another person regarding any matter may file a verified petition in the appropriate court in a county where any expected adverse party resides.

Without leave of court or written stipulation, any party may serve upon any other party written interrogatories, not exceeding 25 in number including all discrete subparts, to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or governmental ...

Rule 26 - Secure-Leave Periods for Attorneys (a)Definition; Entitlement. A "secure-leave period" is one complete calendar week that is designated by an attorney during which the superior courts and the district courts may not hold a proceeding in any case in which that attorney is an attorney of record.

E. A defendant in the civil action may seek discovery from a bankruptcy trust. The plaintiff may not claim privilege or confidentiality to bar discovery and shall provide consent or other expression of permission that may be required by the bankruptcy trust to release information and materials sought by the defendant.

Rule 26 - Secure-Leave Periods for Attorneys (a)Definition; Entitlement. A "secure-leave period" is one complete calendar week that is designated by an attorney during which the superior courts and the district courts may not hold a proceeding in any case in which that attorney is an attorney of record.

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