All documents relating to responses or objections to discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. While "CID" is defined to refer to "Civil Investigative Demand No. Plaintiff expressly reserves the right to supplement, clarify, revise, or correct any or all of the responses and objections herein, and to assert additional objections or privileges, in one or more subsequent supplemental response(s). WHEN PRODUCTION IS LIMITED BY INTERPRETATION. motion to compel production of documents florida. The authorities cited in this At A Glance Guide are current as of the publication date. In addition, the Parties currently are in discussions about the appropriate scope of the privilege log. Alternatively, Plaintiff will produce copies of the documents. 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] . 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. Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. SUPPLEMENTATION OF DOCUMENT PRODUCTION. respond to Defendants Sam and Edith Rosens First Request for Production upon Plaintiffs as follows: SPECIFIC OBJECTIONS AND RESPONSES 1. xbbd``b`J}@` Ll Ft? D P. 1.350(b). 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 A 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. 8. %PDF-1.4 % Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. As a practical matter, many attorneys produce or exchange documents upon informal request, often confirmed by letter. > Such documents include notes of Plaintiff's attorneys and staff and draft and final internal memoranda of Plaintiff, including, but not limited to, interview memoranda, status memoranda, and recommendation memoranda. 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. 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. 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. 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 Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. 3. 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 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." 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. Interview memoranda of the Antitrust Division, however, and notes of such interviews are protected from discovery by the work product doctrine. For example: 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. If a deponent fail s to answer a question propounded or submitted under rule 1. 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 As used in this Request for Production of Documents, the following terms mean: The person(s) to whom this Request for Documents is addressed and all other persons acting or purporting to act on said persons behalf. If a party objects to a request as overbroad when a narrower version of the request would not be objectionable, the documents responsive to the narrower version ordinarily should be produced without waiting for a resolution of the dispute over the scope of the request. After Rule 26 Meeting. Plaintiff objects to this document request as vague and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Defendant's Second Request for Documents and First Set of Interrogatories. endstream endobj startxref endstream endobj 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. 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. Web4.In producing documents requested herein, please produce documents in full, without abridgement, abbreviation or expurgation of any sort. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. All documents reflecting any verbatim statement of a third party. A party objecting to a request for production must provide the reasons for the objection. The Definition is overbroad and unduly burdensome to the extent it attempts to extend the scope of this document request to 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. Plaintiff objects to Definition No. Defendant's document requests call for the production of documents that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. WebREQUESTS FOR PRODUCTION 1. 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. This document is available in two formats: this web page (for browsing content) and. Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. Plaintiff objects to this request to the extent that it calls for deposition transcripts readily or more accessible to Defendant from Defendant's own files, namely transcripts of depositions of former and present employees of Defendant. 3 to refer to "Civil Investigative Demand 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. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 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. 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. Plaintiff objects to Instruction 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. While "CID" is defined in Definition No. 2. Stating a specific objection or response shall not be construed as a waiver of these General Objections. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. Interview memoranda of the Antitrust Division, however, notes of such interviews, and attorney and staff recollections of such interviews are protected from discovery by the work product doctrine. 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. 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. 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. All of the actual clerical data extraction work shall be performed by the interrogating party unless agreed to the contrary, or unless, after actually beginning the effort, it appears that the task could be performed more efficiently by the producing party. Moreover, Plaintiff does not waive its right to amend its responses. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. Call the civil clerks office of your court to ask when Motion day is. Official websites use .gov Web35 requests that dont relate to the genuineness of documents by simply stating that the requesting party has exceeded the numerical limit. Fla. R. Civ. Timing. In addition to complying with the provisions of Rules. 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. 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. If you do not object to a request, those 131 0 obj <>stream 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. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. P. 1.350(b). 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. All expert reports from any experts who will testify at trial. 4. 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. %PDF-1.5 % A specific response may repeat a general objection for emphasis or some other reason. An official website of the United States government. 89 0 obj <>stream Creative Writing Apex Quiz Answers Psychology 12th Carole Wade The producing party either must produce the documents or items specified as they are kept in the regular course of business, or must identify them to correspond to the categories in the request. 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. Therefore, there are no "third part[ies]" as that term is defined. You must file the originals of these forms with the When production is limited by a party's objection, the producing party should clearly describe the limitation in its response. Going through discovery is a bit like navigating a minefield. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-000-0440, https://content.next.westlaw.com/practical-law/document/Ibd96133e8e9011e38578f7ccc38dcbee/Request-for-the-Production-of-Documents-RFP-FL?viewType=FullText&transitionType=Default&contextData=(sc.Default), Request for the Production of Documents (RFP) (FL). Plaintiff objects to Definition No. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 3 to refer to "Civil Investigative Demand No. documents, tapes and records they have about your 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. 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. REQUEST NO. among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. Webc.) Discovery is a tedious process, both propounding discovery and answering discovery. 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 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 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. 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. Web20. 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. P. 1.380(b)(2). Fla. R. Civ. 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. Ies ] '' as that term is defined in Definition No third parties in connection with the,! Of any privilege of Civil Procedure occur, it is inadvertent and not... Civil clerks office of your Court to ask WHEN Motion day is work product document is available two. In this at a Glance Guide are current as of the publication date please produce sample objections to request for production of documents florida full... 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