You and your lawyer will spend many hours on the process. ih3S@k) \S D/)8?/,F{ lA0(s 8ibsc"! Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise. Notwithstanding said objections, Responding Party answers as follows: -See documents attached as Response No. 4 to the extent that it calls for documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. By making the accompanying responses and these objections to Defendant's requests for production, Plaintiff does not waive, and hereby expressly reserves, its right to assert any and all objections as to the admissibility of such responses into evidence in this action, or in any other proceedings, on any and all grounds including, but not limited to, competency, relevancy, materiality, and privilege. WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of the Antitrust Division. 1. Call the civil clerks office of your court to ask when Motion day is. 2 to the extent that it calls for documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. 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 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. WebREQUESTS FOR PRODUCTION 1. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. This is our approach to every case. WebThe most essential and detailed information about List Of Objections To Request For Production Florida is listed here by BestProductToday to make it easy for you to pick out what you want to know. Objected with specificity to objectionable requests and included reasons. Plaintiff further objects to this definition to the extent that it uses the undefined term "during." The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. Words used in discovery normally should carry their plain and ordinary meaning unless the particular case requires a special or technical definition, which should be specified plainly and concisely by the party required to respond to the term(s). Plaintiff will treat this request as if it called for documents (1) that contain, include, or are derived from any statement made by a third party to the DOJ and (2) that were signed and/or adopted, formally or informally, by that third party. Proc., 2033.030(b).) Plaintiff further objects to this request, whether broadly or more narrowly construed, to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. production of documents shielded from discovery based on work product immunity, attorney-client privilege and other applicable privileges and immunities. 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. P. 1.280(b)(5). Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. The failure to include any general objection in any specific response does not waive any general objection to that request. If you need to request documents in an employment discrimination case or if you need to respond to a request for documents from the other side, you can get templates from the Legal Help Centers. 3. Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. Plaintiff's possession, custody or control does not include any constructive possession that may be conferred by the Antitrust Division's right or power to compel the production of documents from third parties or to request their production from other divisions of the Department of Justice or agencies of the United States. 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." Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." 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. b``$+@ + Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. On the motion you also need to put the date and time for the hearing. SUPPLEMENTATION OF DOCUMENT PRODUCTION. A party and counsel ordinarily have complied with the duty to respond to a document request if they have: Responded to the requests within the time set by the governing rule, stipulation, or court-ordered extension. All documents reflecting any verbatim statement of a third party. It is not not far off from the costs. we will unquestionably offer. Attorneys are reminded that informal requests may not support a motion to compel. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. 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. WebFLORIDA RULE OF CIVIL PROCEDURE 1.380: The language of Fla. R. Civ. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. Rule 45 (a) (2) provides that the court where the action is pending issues the subpoena, even if the recipient is not located in that jurisdiction. 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. See Federal Rule of Civil Procedure 33(d). 7. 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. Requests for production are the means by which you can ask the other party to make copies of documents, photographs, records, etc., and to request the inspection of is purposefully implementing that plan in good faith. To learn more about Request for Production of Documents and how to use them, visit www.MassLegalHelp.org and search Request for Production of Documents. Providing such information in answering this interrogatory would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of providing such information in answering this interrogatory is substantially the same or less for Defendant as for Plaintiff. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 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. Stated whether any responsive materials are being withheld on the basis of an objection. These responses and objections are made without prejudice to, and are not a waiver of, Plaintiff's right to rely on other facts or documents at trial. Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiffs Complaint. P. 1.350 (b) (amended eff 10/28/21). Plaintiff objects to Instruction No. 7. 4 regarding "document" or "documents" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. Each request is restated below, along with any applicable objections. Subject to and notwithstanding this objection, Plaintiff will use the more expansive definition of "third party" that it has provided in above Objection 3, and it will treat "statements" as covering those made by the individuals and entities listed in Plaintiff's Rule 26(a)(1) Initial Disclosures during Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. Please produce any and all books, documents or other tangible items relating to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Plaintiff objects to each definition, instruction, and document requests, 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. RESPONDING TO A DOCUMENT REQUEST. An attorney's promise that documents will be produced should be honored. 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. To the extent this request calls for notes and/or memoranda prepared by the potential testifying expert economist, Plaintiff objects to the request as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to the request, 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 set by the Court. P. 1.350(b). D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents and oral testimony and obtained other documents without issuance of a CID. documents, tapes and records they have about your case. 3 to refer to "Civil Investigative Demand No. 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 document request to Civil Investigative Demand Number 13009 itself. Shall be construed either conjunctively or disjunctively to bring within the scope of this Request for Documents any information which might otherwise be construed to be outside their scope. 2. With regard to the 184 individuals and entities who were interviewed by the DOJ pursuant to its CID investigation of Dentsply and subsequently identified in Plaintiff's Rule 26(a)(1) Initial Disclosures, please identify in detail all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 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 Further, the incidents are so numerous that it is impossible to name them all; the main ones are related here, but Complainant reserves the right to supplement this Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. Upon receiving a document request, counsel should promptly confer with the client and take reasonable steps to ensure that the client: understands what documents are requested, has adopted a reasonable plan to obtain documents in a timely and reasonable manner, and. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 4. Stated specifically that no responsive documents have been found. P. 1.380(b)(2). WebIt is your agreed own times to action reviewing habit. A party objecting to a request for production must provide the reasons for the objection. WebThe request is burdensome and oppressive. _ yuj P. 1.350(b). Fla. R. Civ. 3 on the grounds that it is vague and ambiguous, that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence, and that it is overly broad and unduly burdensome, to the extent that it calls for the production of documents in the format as they may be maintained in files outside of the principal investigatory and case files. 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. WebSubpoena for Production of Documents from Nonparty, Florida Supreme Court Approved Family Law Form 12.931(b), is the actual subpoena directing the nonparty to produce specific documents. Web requests for production of documents or to inspect any tangible thing; objections to requests for the production of documents or to inspect any tangible thing; written requests for admission; and answers or objections to written requests for admission; Moreover, Plaintiff does not waive its right to amend its responses. 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. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. A party should, without having to be asked, promptly produce any responsive documents discovered after the original production. PRODUCING DOCUMENTS OVER OBJECTION. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. Indeed, the Court has ordered the parties to disclose the likelihood that they will call those persons as witnesses, and Plaintiff has done so, reducing the list of 184 individuals and entities to 31 individuals whose testimony Plaintiff is very likely or likely to present at trial, either by live testimony or deposition. WebOBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. 3. Produced the documents themselves (or copies), specifically identified those documents that are being or will be produced, or specified precisely where the documents can be found and when they can be reviewed; if the documents will be produced, the response should state a specific date when the responsive documents will be available. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 3. A-_____ _____/ OBJECTION TO DOH SUBPOENA NO. Please produce any and all photographs, videotapes, motion pictures, drawings, sketches, diagrams, plats or the like taken at or made of the scene of the incident or any person or physical object which relate in any way to the circumstances of the incident. They can: WebRequest in an Instructed Language Learning Context Pleadings, Minutes of Public Sittings and Documents / Mmoires, procs-verbaux des audiences publiques et documents, Volume 22 (2015)(2 vols) Budget Request for Operating and Capital Funds Occupational Safety and Health Law Code of Federal Regulations FCC Record This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff deposed a number persons pursuant to various CIDs calling for oral testimony. 6. Please produce any and all correspondence or similar communication between any parties to this action. Furthermore, Civil Investigative Demand 13009 was issued to Dentsply, not to third parties. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. Request for Admission: a written statement that must be admitted or denied. Webthe First Request for Production of Documents of Aurelius Capital Management, LP ("Aurelius"), to the Official Committee of Unsecured Creditors (the "Requests"), as Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. Fla. R. Civ. 7. 6. Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. Plaintiff objects to Definition No. Even so construed, the request is duplicative, overbroad, and burdensome to the extent that it calls for documents already produced to Defendant in response to Defendant's February 2, 1999 Request for Documents, including, but not limited to, documents produced to Plaintiff by third parties, transcripts of the depositions of third parties, and correspondence from third parties to Plaintiff. Objections to requests for production should be specific, not generalized, and should be in compliance with the provisions of. 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. These interviews were conducted by attorneys and staff of Plaintiff. 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