Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. Nearly all, if not all, documents in Plaintiff's files would thus "reflect" some such verbatim statement because to some degree the documents contain information derived from verbatim statements. Judith M. Kinney (DSB # 3643) Assistant United States Attorney 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277, This document is available in two formats: this web page (for browsing content) and. 8. It is not not far off from the costs. This website uses Google Translate, a free service. The failure to include any general objection in any specific response does not waive any general objection to that request. An attorney receiving a request for documents or a subpoena duces tecum shall reasonably and naturally interpret it, recognizing that the attorney serving it generally does not have specific knowledge of the documents sought and that the attorney receiving the request or subpoena generally has or can obtain pertinent knowledge from the client. An official website of the United States government. 8. Web4. If an objection is made only to part of a demand, the objectionable section must be specified. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in which event the reasons for the objection is made to part of an item or category, the part shall be specified. Fla. R. Civ. A party may seek inspection and copying of any documents or things within the scope of rule 12.350(a) from a person who is not a party by issuance of a subpoena directing the production of the documents or things when the The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. 8 regarding documents "in your possession, custody, or control" and "created, transmitted, or received by you" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. Such a reading here demonstrates the problems with the use of this undefined term. endstream endobj 60 0 obj <> endobj 61 0 obj <>/Rotate 0/Type/Page>> endobj 62 0 obj <>stream Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. WebThe request is burdensome and oppressive. Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests and interrogatory, and responses to the requests and interrogatory, to be relevant or material to the subject matter of this action. Share sensitive information only on official, secure websites. Specific objections should Proc., 2033.030(b).) P. 1.280(b)(5). Attendance at such interviews was limited to, at most, the interviewee, Antitrust Division attorneys and staff, counsel for the interviewee (in some interviews), and a potential testifying expert economist (in some interviews). Plaintiff further objects to this instruction as overbroad and unduly burdensome to the extent it seeks (a) documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case, (b) documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant, and (c) documents in possession, custody, or control of the Antitrust Division of the Department of Justice and its present officers, employees, principals, officials, agents, attorneys, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. Plaintiff, by and through its attorneys, and pursuant to Rules 33 and 34 of the Federal Rules of Civil Procedure and the Local Rules of this Court, responds and objects to Defendant Dentsply International, Inc.'s ("Dentsply") Second Request for Documents and First Set of Interrogatories as follows: 1. WebObjections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. ), to whom the referenced Subpoena is directed, by and through his/her undersigned counsel, in accordance with Chapter 120, Florida Statutes, hereby files this Objection and Exceptions to DOH Subpoena No. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce other correspondence to and from third parties, relating to responses or objections to discovery requests, and non-privileged responses and objections to discovery requests obtained during its civil investigation of Dentsply's distribution and marketing of artificial teeth, with the exception that Plaintiff will withhold any correspondence, responses, or objections that may contain confidential information until it receives direction from the Court regarding production pursuant to Local Rule 26.2 or a Protective Order has been entered by the Court allowing the production of that material. Plaintiff further objects to this interrogatory as vague, ambiguous, overbroad, and unduly burdensome to the extent it asks Plaintiff to identify in detail "all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter." Its unnecessary to repeat this line for all subsequent requests, although it may be useful to indicate the numbers of the requests covered by the objection. Therefore, there are no "third part[ies]" as that term is defined. 7. [CCP 2033.010.] REQUEST NO. Subject to the above objections, Plaintiff has no responsive documents in its possession, custody, or control, other than those that have already been produced to Defendant and those being produced as verbatim statements of a third party in response to Request No. Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. 4. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to Plaintiffs Complaint or response to the Complaint. All documents obtained by the DOJ pursuant to its CID investigation of Dentsply's distribution and marketing of artificial teeth. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine, governmental deliberative process privilege, and other privileges protecting such internal documents from discovery. We meet the expense of Sample Objections To Request For Production Of uments and numerous books collections from fictions to scientific research in any way. we will unquestionably offer. When the scope of the document production is narrowed by one or more objections, this fact and the nature of the documents withheld should be asserted explicitly for that request. Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. If a deponent fail s to answer a question propounded or submitted under rule 1. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents and obtained other documents without issuance of a CID. The producing party shall designate one of its regular employees to instruct the interrogating party on the use of the records retention system involved. When producing documents, the producing party shall either produce them Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. This objection encompasses, but is not limited to, documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant. Plaintiff objects to each definition, instruction, and document request as overbroad and unduly burdensome to the extent it seeks documents that are readily or more accessible to Defendant from Defendant's own files or documents that Defendant previously produced to Plaintiff. IH55J6FL"B]Wsng@i! {.C6. 4. While "CID" is defined in Definition No. Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. Webflorida request for production of documents form. COME NOW, REDACTED (BAKER), plaintiff in the above-styled matter, and serves the following requests to produce to REDACTED, INC. (you, your or Defendant) pursuant to Rule 1.350. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine and other privileges protecting such internal documents from discovery. Please produce any and all reports from any accident investigators or reconstruction experts or engineers. All such documents and information will not be produced. WebSample Objections To Request For Production Of Documents Pdf upload Arnold z Ferguson 1/1 Downloaded from filemaker.journalism.cuny.edu on February 26, 2023 by Arnold z Ferguson WebWhere To Download Sample Objections To Request For Production Of Documents Requests must be clear and concise, and request that the RESPONDING TO A DOCUMENT REQUEST. Plaintiff objects to Instruction No. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." endstream endobj After Rule 26 Meeting. Moreover, Plaintiff does not waive its right to amend its responses. %PDF-1.4 % MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrase "CID investigation," unless it is intended to limit the definition of "third party" to those individuals and entities interviewed by Plaintiff pursuant to Civil Investigative Demand Number 13009. xbbd``b`J}@` Ll Ft? D For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. Plaintiff objects to Definition No. Please produce any medical or employment records you have obtained relating to the Plaintiff. SUPPLEMENTATION OF DOCUMENT PRODUCTION. Plaintiff objects to Definition No. WebOBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. WebAsk the judge to order the plaintiff to give you the documents you requested. These interviews were conducted by attorneys and staff of Plaintiff. d.) The Subpoena requests production of documents by RACHLIN of its working papers. Ensured a reasonable inquiry with those persons and a reasonable search of those places likely to result in the discovery of responsive documents. 855 East University Ave.; Gainesville FL 32601, CORONAVIRUS AID, RELIEF AND ECONOMIC SECURITY for FLORIDA. The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. Such materials contain the mental impressions, conclusions, opinions, and legal theories of the Government's attorneys in summarizing the Government's understanding of information obtained in the interview, for instance by the emphasis in memoranda of the specific issues of interest to the Division's legal analysis. Therefore, given the ongoing discussions about the scope of the privilege log and Plaintiff's objections to a request for such a log, Plaintiff will not produce a log of this material at this time. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. Plaintiff objects to each instruction, definition, document request, and interrogatory to the extent that it seeks documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. WebSample Objections To Request For Production Of uments that. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS DOCUMENT REQUEST NO. All such information, prepared in anticipation of litigation and not disclosed or otherwise maintained in a way that is inconsistent with the purpose of the privilege, is protected by the work product doctrine. Plaintiff, by and through its attorneys, and pursuant to Rule 34 of the Federal Rules of Civil Procedure and the Local Rules of this Court, responds and objects to Defendant Dentsply International, Inc.'s ("Dentsply") Request for Documents as follows: 1. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrase "CID investigation," unless it is intended to limit the document request to material produced in response to Civil Investigative Demand Number 13009. P. 1.350(b). The producing party shall make available any computerized information or summaries that it either possesses or can produce by a reasonably efficient procedure. Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks information that is readily or more accessible to Defendant from Defendant's own files, including, but not limited to, interrogatory answers that Defendant produced to Plaintiff, transcripts of depositions of current or former directors, officers, and employees of Defendant, documents that Defendant produced to Plaintiff, and correspondence and other communications from Defendant to Plaintiff. 6. In the course of its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff interviewed a number of individuals, but interviewed none pursuant to Civil Investigative Demand Number 13009, a document request issued to Dentsply. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. documents, tapes and records they have about your case. 3. Fla. R. Civ. WebIt is your agreed own times to action reviewing habit. Going through discovery is a bit like navigating a minefield. 7. Fla. R. Civ. Plaintiff objects to this document request as overbroad, burdensome, vague, and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Dentsply's Second Request for Documents and First Set of Interrogatories. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." Plaintiff further objects to this request to the extent that it requires the production, prior to the entry of a Protective Order by the Court and prior to instruction from the Court as to production pursuant to Del. endstream endobj 120 0 obj <>/Metadata 18 0 R/Pages 117 0 R/PageLayout/OneColumn/StructTreeRoot 22 0 R/Type/Catalog/Lang(en)>> endobj 121 0 obj <>/Font<>>>/Type/Page>> endobj 122 0 obj <>stream The failure to include any general objection in any specific response does not waive any general objection to that request. Without waiving this objection and to the extend I understand this question, a copy of a citation for failure to yield dated January 31, 2014, is provided with these responses. Our goal is to help people in the best way possible. 2. Attorneys should not make objections solely to avoid producing documents that are relevant to any party's claim or defense and proportional to the needs of the case. WebA sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other tangible items from another party. 2. Plaintiff will produce responsive documents only to the extent that such documents are in the possession, custody, or control of the Antitrust Division of the U.S. Department of Justice, as set forth in the Federal Rules of Civil Procedure. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." This request, in essence, then, asks for the recollections of the attorneys representing the United States, or of the staff working under their direction, or for information contained in memoranda and notes prepared by those attorneys and their staff. Therefore, there are no "statements" as that term is defined. Webregarding requests for production of documents. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents, information, and oral testimony and obtained other documents and information without issuance of a CID. Include all documents and 1. Here are the top five considerations when representing a non-party who receives a subpoena for production of documents. Document Production in International Arbitration - Reto Marghitola 2015-10-20 Because document production can discover written evidence that would otherwise not be available, it is Secure .gov websites use HTTPS PRODUCING DOCUMENTS OVER OBJECTION. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. Webthose all. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. P. 1.350(b). Official websites use .gov Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails and recordings (tape, disc or other) of oral communications. To the extent any of Defendant's document requests seek documents that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports to be determined by the Court. Copy of marriage certificate if a derivative claim is being made for loss of consortium, loss of service, or any other claim by your spouse as a result of personal Timing. entities owning the property where the plaintiff was injured, as described in the Complaint. Fla. R. Civ. This Standard Document has integrated drafting notes with important explanations and drafting tips. The request is irrelevant to the underlying nature of this proceeding. Plaintiff objects to Definition No. Copies of certain materials, including internal memoranda to which documents obtained from outside parties may have been attached, are circulated to and may be maintained in files kept in Antitrust Division files other than the principal investigatory and case files. Plaintiff obtained any responsive information, other than the information that Defendant may derive from the materials described in the preceding paragraphs, from interviews of individuals by attorneys and staff of Plaintiff. hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< ORAL REQUESTS FOR PRODUCTION OF DOCUMENTS. As set forth in the correspondence dated March 3, 1999 from Michael S. Spector to Kelly A. Clement, Plaintiff objects to the production of those parties' confidential documents and will not produce those documents unless directed by the Court to do so pursuant to Del. The process can be very difficult, for all parties involved. WebFLORIDA RULE OF CIVIL PROCEDURE 1.380: The language of Fla. R. Civ. The Parties currently are in discussions about the appropriate scope of the privilege log. 5. Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests or responses thereto to be relevant or material to the subject matter of this action. READING AND INTERPRETING REQUESTS FOR DOCUMENTS. Request for Production in Florida Circuit Court At A Glance, Ex Parte Motion in United States District CourtAt A Glance, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. P. 1.380(b)(2). Plaintiff further objects to this request to the extent that it requires the production, prior to the entry of a Protective Order by the Court and prior to instruction from the Court as to production pursuant to Del. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce copies of those CIDs and correspondence requesting documents and information from third parties. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these While "CID" is defined to refer to "Civil Investigative Demand No. 2. We meet the expense of Sample Objections To Request For Production Of uments and numerous books collections from fictions to scientific research in any way. 4. Notwithstanding these objections, Respondent will commence his production in response to the following Request to the extent possible. Plaintiff objects to each instruction, definition, document request, and interrogatory as overbroad and unduly burdensome to the extent it seeks documents or information that are readily or more accessible to Defendant from Defendant's own files, from documents or information in Defendant's possession, or from documents or information that Defendant previously produced to Plaintiff. Plaintiff objects to Instruction No. If an objection is made to part of an item or category, the part shall be specified. 2 regarding "DOJ." 76 0 obj <>/Filter/FlateDecode/ID[]/Index[59 31]/Info 58 0 R/Length 87/Prev 100751/Root 60 0 R/Size 90/Type/XRef/W[1 2 1]>>stream The party serving the request for production may move for an order compelling production under Rule 1.380. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrase "CID investigation," unless it is intended to limit the definition of "statement" to any comment, observation, remark, observation, or affirmation, whether in written or oral form, made by a third party to Plaintiff during the Civil Investigative Demand Number 13009 investigation. 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