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. 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. While "CID" is defined to refer to "Civil Investigative Demand No. P. 1.350 (b) (amended eff 10/28/21). Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. 5. 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. 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. Webthose all. 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 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. Objections to requests for production should be specific, not generalized, and should be in compliance with the provisions of. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. Alternatively, Plaintiff will produce copies of the documents. 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 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 previously produced by Defendant to the Antitrust Division of the Department of Justice in the course of the antitrust investigation leading up to the filing of this case, transcripts of depositions of employees and former employees of Defendant, correspondence between the Plaintiff and 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, attorney, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." 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. The producing party shall designate one of its regular employees to instruct the interrogating party on the use of the records retention system involved. The party serving the request for production may move for an order compelling production under Rule 1.380. Plaintiff will construe "during" to mean "in the course of.". WebSample Objections To Request For Production Of uments that. P. 1.350(b). For example: Web4.In producing documents requested herein, please produce documents in full, without abridgement, abbreviation or expurgation of any sort. Proc., 2033.030(b).) Web Produce documents, information, or objects, or to permit inspection of premises, is the AO 088B. 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 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 incorporates by reference every general objection set forth above into each specific response set forth below. xb```"7 Fm cjMf\ V5p 4,PpSOK #H3-W, "` f Plaintiff further objects to Definition No. PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECONDREQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. Plaintiff objects to each instruction, definition, document request, and interrogatory 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. _ yuj among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. Stating a specific objection or response shall not be construed as a waiver of these General Objections. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." 2. 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. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. 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. After Rule 26 Meeting. 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. 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. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. Furthermore, attorneys are reminded that evasive or incomplete disclosures, answers, or responses may be sanctionable under the provisions of. 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. Web2. Interview memoranda of the Antitrust Division, however, and notes of such interviews are protected from discovery by the work product doctrine. Procedural Law v. Substantive Law What Is The Differance? Webthose all. 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." Share sensitive information only on official, secure websites. in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. 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. 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. P. 1.380 applies to all discovery: depositions, admissions, responses to requests to produce, etc. Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. WebWith respect to each document produced, identify the person producing the document and the paragraph or subparagraph number of the request. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. Thus, a request for production of document may be compound. 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. Webthe First Request for Production of Documents of Aurelius Capital Management, LP ("Aurelius"), to the Official Committee of Unsecured Creditors (the "Requests"), as Web35 requests that dont relate to the genuineness of documents by simply stating that the requesting party has exceeded the numerical limit. Plaintiff objects to Definition No. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. endstream endobj 123 0 obj <>stream b``$+@ + Notwithstanding said objections, Responding Party answers as follows: -See documents attached as Response No. Secure .gov websites use HTTPS A specific response may repeat a general objection for emphasis or some other reason. 3. Civil Investigative Demand Number 13009 was not an investigation, it was a document request. Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. 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. 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. 6. Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. 22. WebRequests for production of documents or things, which are written requests that demand the other side provide particular documents or items. 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. WHEN PRODUCTION IS LIMITED BY INTERPRETATION. 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. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. 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. WebThe request is burdensome and oppressive. They can: WebIt is your agreed own times to action reviewing habit. Our goal is to help people in the best way possible. 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. 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. Fla. R. Civ. x!S1_OjVDNBfwLVw\{`fxXtlW?tH>i]SHb/zp1y(({!;je@4I:CR~n3+)(J&Z[n3[~,xG#'ot?IM5 |T.]>D_#bXX?O a}BRa}dwXXP See Objections 3-4 to Instructions and Definitions ("Objections 3-4"). See Federal Rule of Civil Procedure 33(d). The Parties currently are in discussions about the appropriate scope of the privilege log. 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). Webflorida request for production of documents form. 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. 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. While "CID" is defined in Definition No. 6. WebObjections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. 3. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. Z [ n3 [ ~, xG # 'ot? IM5 |T the currently! The party serving the request undefined term `` CID '' is defined to to! 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