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. Specific objections should This document is available in two formats: this web page (for browsing content) and. 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. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. 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. 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. In its Response to Document Request No. 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. 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. 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 Our goal is to help people in the best way possible. 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. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. A specific response may repeat a general objection for emphasis or some other reason. 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. 22. 4. WebSample Objections To Request For Production Of uments that. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. if the request just reads, Produce the documents you showed me, the request would be vague or ambiguous, since you might have shown the requesting party This objection encompasses, but is not limited to, documents previously produced by Defendant to the Antitrust Division of the Department of Justice during the Antitrust Division's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, and all correspondence between the Plaintiff and Defendant. When production is limited by a party's objection, the producing party should clearly describe the limitation in its response. 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. RFAs are a powerful trial-preparation tool. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade 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. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade [CCP 2033.010.] At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. 2: All business licenses currently standing in your name or for any entity for WebIt is your agreed own times to action reviewing habit. Thus, a request for production of document may be compound. Stated specifically that no responsive documents have been found. hbbd``b`$@`6 $1U@ cB Xp 7. Nor have such notes and/or memoranda of interviews been seen by anyone other than the case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. Please produce any medical or employment records you have obtained relating to the Plaintiff. 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. Plaintiff objects to this request to the extent that it calls for documents readily or more accessible to Defendant from Defendant's own files, including without limitation documents produced by the Defendant to Plaintiff. This disclosure will allow Defendant to identify those individuals from whom it needs detailed information. On the motion you also need to put the date and time for the hearing. 6. Request for Admission: a written statement that must be admitted or denied. 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 3 to refer to "Civil Investigative Demand No. Neither should burdensome "boilerplate" definitions or instructions be used in formulating a document request or subpoena. P. 1.280(e). Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiff to reproduce, in narrative answer format, material from third parties that has already been produced to defendant. motion to compel production of documents florida. 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. Documents already produced will not be produced again. 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. 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. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 7. Plaintiff will construe "during" to mean "in the course of.". 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. 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. See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). 21. It is not not far off from the costs. WebREQUESTS FOR PRODUCTION 1. 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 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. Webregarding requests for production of documents. An attorney's promise that documents will be produced should be honored. D. Ct. Local Rule 26.2 or pursuant to a Protective Order entered by the Court. 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. 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 further objects to this definition to the extent that it uses the undefined term "during." These interviews were conducted by attorneys and staff of Plaintiff. A-_____ _____/ OBJECTION TO DOH SUBPOENA NO. A party should, without having to be asked, promptly produce any responsive documents discovered after the original production. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS DOCUMENT REQUEST NO. 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. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? 2 regarding "DOJ." 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. Requests for production of documents and responses may be made on the record at depositions but usually should be confirmed in writing to avoid uncertainty. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp 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; 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. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 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 (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. P. 1.350(b). 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. Plaintiff objects to Definition No. 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. > hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ 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. 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. Fla. R. Civ. P. 1.350(b). PRODUCING DOCUMENTS OVER OBJECTION. Requests for Production United States District Court Southern District of Florida. Plaintiff can only know those facts, of which it is aware, that are known to such individuals and entities. 2. Plaintiff objects to Instruction No. List Of Objections To Request For Production Florida - Every nearest and informative results for your search Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. 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. WebRequests for Production Like interrogatories, requests for production are made in writing, they must be answered within 30 days and they are only between the parties. 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 documents, tapes and records they have about your case. Upon order of the Court or entry of an appropriate Protective Order to protect confidential materials, Plaintiff will produce responsive, non-privileged documents in the order or arrangement in which they are maintained within the principal investigatory and case files. Timothy J. Corrigan, Chief United States District Judge Elizabeth Warren, Clerk of Court. Discovery is a tedious process, both propounding discovery and answering discovery. 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. 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. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. endstream endobj 123 0 obj <>stream For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. 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. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not 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. 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. In that event, the interrogating party may ask the Court to review the propriety of the. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 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. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. b``$+@ + Fla. R. Civ. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best 2. Please produce any and all correspondence or similar communication between any parties to this action. Webc.) Requests for Admissions (RFAs) permit any party to request any other party to admit: (1) the truth of specified matters of fact, opinion relating to fact, or application of law to fact; or (2) the genuineness of specified documents. WebThe request is burdensome and oppressive. 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. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best Moreover, Plaintiff does not waive its right to amend its responses. 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. USE OF FORM REQUESTS. Sunny Balwani Sentenced Is This the Final Theranos Chapter. While "CID" is defined in Definition No. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? All transcripts of oral testimony (via deposition) taken by the DOJ pursuant to the CID investigation, including transcripts of third party CID witnesses. 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 Instruction No. Such a reading here demonstrates the problems with the use of this undefined term. 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. WebA sample response to a subpoena duces tecum that a nonparty may use to respond and object to a subpoena seeking production of documents (with or without a deposition) in Florida civil litigation. Fla. R. Civ. 5. All documents reflecting any verbatim statement of a third party. Plaintiff objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." While "CID" is defined to refer to "Civil Investigative Demand No. 131 0 obj <>stream response to request for production florida sample. 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 will produce responsive, non-privileged documents in the order or arrangement in which they are maintained within the principal investigatory and case files. 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. Webthose all. 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. The information or documents See Objections 3-4 to Instructions and Definitions ("Objections 3-4"). The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. Any individual, corporation, partnership, joint venture, firm, association, proprietorship, agency, board, authority, commission or any other entity. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than RESPONDING TO A DOCUMENT REQUEST. 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. 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. 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. _ yuj 310 or 1.320, or a corporati on or other entity fails to Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation" and "CID witnesses." 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