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The party on whom the request is served shall serve a written response within 35 days after the service of the request, except that a defendant may serve a response within 50 days after service of the summons and complaint on that defendant. On motion, the court may allow a shorter or longer time.
Discovery of communications between an attorney and any expert retained or specially employed by that attorney is limited to facts and data considered by the expert in rendering the report.
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.
This discovery deficiency letter is a standard form that attorneys can use in a federal court litigation to facilitate a discussion with opposing counsel concerning his or her failure to respond to discovery requests or provision of inadequate, incomplete, or otherwise deficient responses.
Grounds for Motion to Compel If a deponent fails to answer a question propounded or submitted orally or in writing, or a corporation or other entity fails to make information available, the discovering party may move for an order compelling an answer or designation in ance with the request. N.J.R. -1(a).
If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.
By signing, an attorney or party certifies that to the best of the person's knowledge, information, and belief formed after reasonable inquiry: (1) with respect to a disclosure, it is complete and accurate as of the time it is made; and (2) with respect to a discovery request, response, or objection, it is: (A) ...
This template discovery deficiency letter may be used in New Jersey state court litigation to facilitate compliance with N.J. Ct. R. , when a party upon whom you have served discovery requests has either failed to respond or has given a response that is inadequate, incomplete, or otherwise deficient.