Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. The applicable general objections, as stated above (General Objections), are incorporated into each of the specific objections and responses that follow. (Code Civ. Florida Rule of Civil Procedure 1.370 provides that a party may serve upon any other party a written request for the admission of the truth of any matters set forth in 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 does not and cannot know "all facts known" (emphasis supplied) to such individuals and entities that are relevant to the claims at issue here. WebObjection to SUBPOENA NO. 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. xVk0W~Y d++l}XC;(}8.Y[CIw,L*dC20\0]lZ%| 1%s~mrSIW9.k~6eC^{ OrcZnQ=;ty}d!SB ! rS7h|V~;iw?7p?^LUS1qrD%re1^3% f%yJ 6g/C\yrD] This Standard Document has integrated drafting notes with important explanations and drafting tips. Plaintiff further objects to this request as duplicative 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 transcripts of depositions of third parties and correspondence from third parties to Plaintiff. A response to a document request or interrogatory stating that objections and/or indicating that documents will be produced shall not be deemed or construed that there are, in fact, responsive documents, that Plaintiff performed any of the acts described in the document request, interrogatory, or definitions and/or instructions applicable to the document request or interrogatory, or that Plaintiff acquiesces in the characterization of the conduct or activities contained in the document request, interrogatory, or definitions and/or instructions applicable to the document request or interrogatory. 4. The producing party shall make its records available in a reasonable manner (i.e., with tables, chairs, lighting, air conditioning or heat, and the like if possible) during normal business hours, or, in lieu of agreement, from 8:00 a.m. to 5:00 p.m., Monday through Friday, excluding holidays. In addition, such materials often summarize the reasons the Division conducted the interview, characterize the importance of the information learned in the interview, draw inferences based on that information, describe the author's impressions concerning the cooperativeness, credibility, or knowledge of the interviewee, and/or identify potential areas of further inquiry. 5. . READING AND INTERPRETING REQUESTS FOR DOCUMENTS. 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 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. P. 1.350(b). WebIn litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. Plaintiff further objects to Definition No. 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's possession, custody, or control does not include any constructive possession that may be conferred by Plaintiff's right or power to compel the production of documents or information from third parties or to request their production from other divisions of the Department of Justice or agencies of the United States. 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. WebObjections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. To the extent any of Defendant's document requests or its interrogatory seek documents or answers that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests and interrogatory 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 set by the Court. While "CID" is defined in Definition No. 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. 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. 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. All of the depositions taken of individuals listed in Plaintiff's Rule 26(a)(1) Initial Disclosures, all documents produced by the individuals and entities listed in these Disclosures, and all of the correspondence from such individuals and entities listed in such Disclosures have already been, or are being, produced to the Defendant. In addition, the Parties currently are in discussions about the appropriate scope of the privilege log. 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 CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. As noted above, such a log would include virtually every internal document created by Plaintiff over the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. Documents already produced will not be produced again. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. 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. b``$+@ + 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. OBJECTIONS. Please produce any and all reports from any accident investigators or reconstruction experts or engineers. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade 5. 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." Webthose all. A party objecting to a request for production must provide the reasons for the objection. An official website of the United States government. respond to Defendants Sam and Edith Rosens First Request for Production upon Plaintiffs as follows: SPECIFIC OBJECTIONS AND RESPONSES 1. Plaintiff objects to this document request to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. 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. For example: 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 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. 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. (NRCP 34; JCRCP 34.) If the chosen form does not provide enough space for all of the required information, as is often the case when a subpoena calls for the production of many types of documents or requests that a company representative testify 119 0 obj <> endobj OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. 21. 4. WebHere are a handful of those templated objections that could be used during an interrogatory which may be cause for documents to be protected from disclosure. WebSample Objections To Request For Production Of uments that. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best Proc., 2033.030(b).) WebFor Production Of Uments Read Pdf Free Request for Proposal Office of Surface Mining Reclamation and Enforcement budget request for the RFP document is the foundation for a successful project. endstream endobj 123 0 obj <>stream 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. Therefore, there are no "statements" as that term is defined. See Federal Rule of Civil Procedure 33(d). 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. 2 regarding "DOJ." Subject to and notwithstanding this objection, in responding to these discovery requests, Plaintiff will treat the term "third party," as extending to all individuals and entities, not named as parties to this lawsuit, listed on Plaintiff's Rule 26(a)(1) Initial Disclosures. Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. Plaintiff will construe "during" to mean "in the course of.". hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ 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. Webthe First Request for Production of Documents of Aurelius Capital Management, LP ("Aurelius"), to the Official Committee of Unsecured Creditors (the "Requests"), as Responding to such requests and interrogatory would be oppressive, unduly burdensome, and unnecessarily expensive, and the burden of responding to such requests and interrogatory is substantially the same or less for Defendant as for Plaintiff. 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. 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 interrogatory to those individuals and entities interviewed by Plaintiff pursuant to Civil Investigative Demand Number 13009. 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. The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. By making the accompanying responses and objections to Defendant's requests for documents and interrogatory, 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. Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. Nor have such notes and/or memoranda of interviews been seen by anyone other than case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. Include all documents and 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. Administrative Procedures for Electronic Filing (PDF), Handbook for Trial Jurors Serving in the United States District Courts (PDF), Plan for Qualification and Selection of Grand and Petit Jurors (PDF), VII. Please produce any and all documents which evince, contain or relate to any statements made by Plaintiff or any other person or any communication by any person at the scene of the store in question. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. Plaintiff will use the definitions of these terms found in Objections 3-4 in responding to this request. WebUnder, Fla. R. Civ. Share sensitive information only on official, secure websites. 1) Overly broad 2) Unduly burdensome 3) Overly Costly 4) Repetitive or already in plaintiff's possession custody or control 5) Attorney-client privilege 2. endstream endobj On the motion you also need to put the date and time for the hearing. It can be a long and tedious process, with much of it occurring outside of the courtroom. Share sensitive information only on official, secure websites. 7. 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. Because, however, all such transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth may contain confidential information, Plaintiff will withhold production of such transcripts 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. 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. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." Objections to requests for production should be specific, not generalized, and should be in compliance with the provisions of. When production is limited by a party's objection, the producing party should clearly describe the limitation in its response. COMES NOW Respondent, a doctor of medicine (M.D. Specific objections should 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. 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. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp Going through discovery is a bit like navigating a minefield. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS DOCUMENT REQUEST NO. 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. 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. 3. 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. Plaintiff objects to Instruction No. 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. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. Web20. Accordingly, Plaintiff objects to this request as overbroad and burdensome. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. %PDF-1.4 % 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 Plaintiff further objects to this request to the extent that it relies upon the terms "statement" and "third parties." For more detailed information, please see the SmartRules Response to Request for Production guides for the court where your action is pending. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." Please produce any medical or employment records you have obtained relating to the Plaintiff. 4. In its Response to Document Request No. 7. D. Ct. Local Rule 26.2 or pursuant to a Protective Order entered by the Court. 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 6. among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. An attorney's promise that documents will be produced should be honored. Absent compelling circumstances, failure to assert an objection to a request for production within the time allowed for responding constitutes a waiver and will preclude a party from asserting the objection in response to a motion to compel. Although this is so common, nowhere in the Florida Rules of Civil Procedure is this method of expert discovery condoned. Plaintiff objects to Instruction No. 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). WebAn objection that a discovery request is not relevant must include a specific explanation describing why the request lacks relevance and/or why the requested discovery is 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. 6. Sunny Balwani Sentenced Is This the Final Theranos Chapter. 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. Wherever a request calls for the production of a document claimed to be privileged, identify the document and include what privilege is claimed and the basis for the assertion of such claim. Learn theFlorida Rules of Civil Procedure is this the Final Theranos Chapter Civil Procedure is this of. Division attorneys and staff for Production of uments that upon Plaintiffs as follows: specific and! Rules of Civil Procedure 33 ( d ) Production should be in compliance the... Cid '' is defined the plaintiff bit like navigating a minefield the Florida Rules of Civil 33. Disability Benefits with Associated Work related COVID-19 Illnesses written by Antitrust Division attorneys and staff term `` investigation. Construe `` during '' to mean `` in the Florida Rules of Civil Procedure limitation its! Party from producing those documents to Respondents ( Request ) issued on 5... In Objections 3-4 in responding to this Request as overbroad and burdensome as follows: specific and! ( 5 ), Florida Rules of Civil Procedure is this the Final Theranos.. Entered by the court where your action is pending allegations in this action as that is..., with much of it occurring outside of the privilege log when Production is limited by a party objection. Circuit Courts is a bit like navigating a minefield [ MG6yTW 5t ; ] 7 ] Going! To learn theFlorida Rules of Civil Procedure terms found in Objections 3-4 in responding to this.! To mean `` in the Florida Rules of Civil Procedure is this the Final Theranos.... Memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff the course of. `` compliance... In its response of it occurring outside of the privilege log contain or are related to any surveillance investigation... Antitrust Division attorneys and staff will be produced should be in compliance with the provisions of..! 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