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. Civil Investigative Demand Number 13009 was not an investigation, it was a document request. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. Timothy J. Corrigan, Chief United States District Judge Elizabeth Warren, Clerk of Court. _ yuj 1. 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. On the motion you also need to put the date and time for the hearing. 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. 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. Fla. R. Civ. 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. 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. 59 0 obj <> endobj Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. The Florida Judicial Qualifications Commission, by and through its undersigned counsel and pursuant to Fla. A specific response may repeat a general objection for emphasis or some other reason. 21. 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). Its more or less what you craving currently. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. 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. Webthose all. All documents, papers or evidence to be introduced at trial. RFAs are a powerful trial-preparation tool. If it has any documents arguably subject to this requirement but which it declines to produce for some reason, the producing party shall call the circumstances to the attention of the opposing party, who may move to compel. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. WebREQUESTS FOR PRODUCTION 1. This disclosure will allow Defendant to identify those individuals from whom it needs detailed information. As computerized translations, some words may be translated incorrectly. 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. Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. D. Ct. Local Rule 26.2 or pursuant to a Protective Order entered by the Court. Going through discovery is a bit like navigating a minefield. Fla. R. Civ. 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. 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. Webregarding requests for production of documents. Secure .gov websites use HTTPS At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. Timing. 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. Plaintiff objects to Instruction No. 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. 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. (NRCP 34; JCRCP 34.) 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 Plaintiff further objects to this request as duplicative, overbroad, and burdensome even if the term "reflected" were construed more narrowly to include only documents containing or including verbatim statements. 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. 4. 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. Its more or less what you craving currently. 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. 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. 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. 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. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. Any and all land records, contracts, documents or the like reflecting the persons or. 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. If a party fails to respond to a request for production, the propounding party may move for an order compelling production under Rule 1.380. 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 Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. WHEN PRODUCTION IS LIMITED BY INTERPRETATION. 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. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. A- The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 2 regarding "DOJ." 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. %%EOF Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. In addition to complying with the provisions of Rules. 5. * Not Reasonably Particularized C.C.P. In addition, the Parties currently are in discussions about the appropriate scope of the privilege log. Thus, a request for production of document may be compound. 7. response to request for production florida sample. Subject to and without waiver of the foregoing objections, Plaintiff will produce the documents responsive to this request that have not already been produced and are not protected by the privileges listed above. 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. Share sensitive information only on official, secure websites. Please produce any and all correspondence or similar communication between any parties to this action. Your response to this request should be periodically supplemented. P. 1.380(b)(2). hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< Please produce copies of all pleadings, orders, police reports, notices or other documents pertaining to the incident. 3. Therefore, there are no "statements" as that term is defined. Plaintiff further objects to Definition No. 6. WebAsk the judge to order the plaintiff to give you the documents you requested. 6. 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. 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. 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. Reflecting the persons or ( 5 ), Florida Rules of civil Procedure translated incorrectly,! Addition, the parties currently are in discussions about the appropriate scope the... 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