Tennessee 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

RULE 37. A party, upon reasonable notice to other parties and all persons affected thereby, may apply for an order compelling discovery as follows: (1) APPROPRIATE COURT. An application for an order to a party or to a deponent who is not a party, may be made to the court in which the action is pending. (2) MOTION.

If a request, response, or objection is not signed, it shall be stricken unless it is signed promptly after the omission is called to the attention of the party making the request, response or objection and a party shall not be obligated to take any action with respect to it until it is signed.

Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.

They are provided for your information. 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.

Rule 26.02(4) of the Tennessee Rules of Civil Procedure states as follows:Discovery of facts known and opinions held by experts, otherwise discoverable under the provisions of subdivision (1) of this rule and acquired or developed in anticipation of litigation or for trial, may be obtained only as follows:(A)(i) A ...

Expert disclosures. 1. Under Tennessee Rule 26.02(4)(a)(i), a party may through interrogatories require any other party to identify experts who they expect to call at trial and to provide a summary of the facts and opinions to which the expert is expected to testify, among other things.

RULE 34. PRODUCTION OF DOCUMENTS AND THINGS AND ENTRY UPON LAND FOR INSPECTION AND OTHER PURPOSES. The request may, without leave of court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party.

RULE 7. PLEADING ALLOWED; FORM OF MOTIONS. (1) An application to the court for an order shall be by motion which, unless made during a hearing or trial, shall be made in writing, shall state with particularity the grounds therefor, and shall set forth the relief or order sought.

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