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How to present a losing objection: Make it a lead-off general objection. Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection.
What Is a Request for Production of Documents? A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
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.
Step 1: Carefully Review All the Requests. Review each request to ensure you fully understand the question, and can answer it completely.Step 2: Complete Your Responses to the Interrogatories.Step 3: Make Photocopies.Step 4: Have Your Responses Served.Step 5: Retain Your Documents.
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.
In a civil action, an interrogatory is a list of questions one party sends to another as part of the discovery process. The recipient must answer the questions under oath and according to the case's schedule.
Interrogatories must be answered in writing under oath by the party on whom they are served or, in the case of business and public entities, by an officer or agent who can furnish all information available to the party. N.J.R. -4 (a) (amended eff 9/1/14).
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.
Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.
IMPORTANT TIPS Organize documents. Organize according to the demand number.Don't duplicate documents. If you're providing three years of bank statements in response to one demand, and the same documents contain information responsive to another demand, state so.Comply with the due date.Communicate.Do a complete job.