Houston Texas Responses To Defendant's First Request For Production To Plaintiff
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How to fill out Responses To Defendant's First Request For Production To Plaintiff?
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FAQ
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.
WITHOUT WAIVING THESE DEFENSES, I RESPOND AS FOLLOWS: 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).
The responding party must serve a written response on the requesting party within 30 days after service of the request, except that a defendant served with a request before the defendant's answer is due need not respond until 50 days after service of the request.
(4) Requests for Production. Any party may serve on any other party no more than 15 written requests for production. Each discrete subpart of a request for production is considered a separate request for production.
A party must respond to written discovery in writing within the time provided by court order or these rules. When responding to written discovery, a party must make a complete response, based on all information reasonably available to the responding party or its attorney at the time the response is made.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Typically, you may admit, deny, or claim that you neither admit nor deny a request. You may also partially agree with the request and disagree with the other. In such a case, you must indicate which part you admit to and which part you deny in your response.
If the other side does not think that your objection is valid, s/he may be able to file a motion to compel, which basically asks the judge to force you to answer the interrogatories. The judge will then decide whether the question in the interrogatories must be answered or not.
If you are on the receiving end of an RFI, here are some good pointers on how to respond. Don't be afraid to ask questions. If there is any part in the RFI that is unclear or ambiguous, don't be afraid to seek clarification from the sender.Promptly deal with an incoming RFI.Respond as accurately as you can.
WITHOUT WAIVING THESE DEFENSES, I RESPOND AS FOLLOWS: 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).