Sample Responses to Requests for Documents

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Sample Responses to Requests for Documents Powered By Docstoc
					 1   Any Party
     Any Street
 2   Any Town, CA 55555
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     714-555-5555
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 5   Defendant, In Pro Per

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                                    Superior Court of the State of California
                                     For the County of ________________
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11   Any Plaintiff,                                  ) Case No.
                                                     )
12                                                   ) Responses to Requests for Production of
                      Plaintiff,                     ) Documents, Set One
13                                                   )
            vs.                                      )
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     Any Defendant, and DOES 1-5                     )
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                                                     )
                                                     )
                      Defendants.                    )
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                                                     )
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18   PROPOUNDING PARTY: ANY PLAINTIFF
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     RESPONDING PARTY:              ANY DEFENDANT
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     SET NO.:                       ONE
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            TO ANY PLAINTIFF AND HIS COUNSEL OF RECORD:
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23           Defendant hereby responds to Plaintiff’s First Set of Requests for Production of Documents
     as follows:
24                                           General Statement
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            These responses are made solely for the purposes of this action. Each answer is subject to
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                                                 - 1 -
                      RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1   all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all

 2   other objections and grounds which would require the exclusion of any document herein if the
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     request for production, or any documents contained herein were made by, a witness present and
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     testifying in court, all of which objections and grounds are reserved and may be interposed at the
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     time of trial.
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 7           Except for explicit facts admitted herein, no answer or implied admissions are intended

 8   hereby. The fact that respondent answered any request for production shall not be taken as an
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     admission that respondent accepts certain events or admits the existence of any fact set forth or
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     assumed by such request for production, or that such response constitutes admissible evidence. The
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     fact that respondent answered part or all of the request for production is not intended and shall not be
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13   construed to be a waiver of all or any part of any objection to any request for production made by

14   respondent.
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             The factual background of this litigation is complex. Respondent will, during the course of
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     this litigation, pursue extensive formal discovery, as well as extensive investigation and informal
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     discovery. The following responses are
				
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