Nevada 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

You have 30 days to respond to the interrogatories. If you were served by mail, you typically have 35 days from the date of mailing to respond. Just below the top caption identifying the case, the form identifies the Answering (or Responding) party. Make sure that this is you.

(A) No party may serve upon any other single party to an action more than 40 requests for admission under Rule 36(a)(1)(A) without obtaining: (i) a written stipulation under Rule 29 of the party to which the additional requests are directed; or (ii) upon a showing of good cause, a court order granting leave to serve a ...

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.?

Write simple requests for categories of documents that are relevant to your case. There is not a specific limit on the number of requests, but the other party may object if responding would cause an unfair burden.

There should be only three goals in answering interrogatories: accurate, complete, minimal. Accuracy is important because, pursuant to Rule 33(a), SCRCP, these answers are verified by the client under oath and, under Rule 801(d)(2), SCRE, are admissions of a party opponent.

If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.

Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...

However, the rule places no limits on the number of requests which may be made of either litigant. State court rules, however, may be stricter than this. Notably, under Rule 36(a)(3), requests for admission are automatically deemed admitted in U.S. federal courts if the opponent fails to timely respond or object.

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.

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.

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