1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 UNITED STATES DISTRICT COURT

9 ___________ DISTRICT OF __________

10

11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) RESPONSES TO REQUESTS TO PRODUCTION
) OF DOCUMENTS, SET ONE
13 vs. )
)
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
17

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- 1 -
RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 PROPOUNDING PARTY: Any Plaintiff
2
RESPONDING PARTY: Any Defendant
3
SET NUMBER: One
4
TO _______________AND THEIR COUNSEL OF RECORD:
5

6 Pursuant to the provisions of Federal Rules of Civil Procedure 26 and 34, ___________herein

7 responds and objects as follows to the Requests for Production of Documents, Set One propounded
8
by ___________.
9

10
Dated________________ _______________________________________________
11 ANY ATTORNEY OR PARTY
12
General Statement
13
These responses are made solely for the purposes of this action. Each answer is subject to
14

15 all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all

16 other objections and grounds which would require the exclusion of any document herein if the
17 request for production, or any documents contained herein were made by, a witness present and
18
testifying in court, all of which objections and grounds are reserved and may be interposed at the
19
time of trial.
20

21
Except for explicit facts admitted herein, no answer or implied admissions are intended

22 hereby. The fact that respondent answered any request for production shall not be taken as an

23 admission that respondent accepts certain events or admits the existence of any fact set forth or
24
assumed by such request for production, or that such response constitutes admissible evidence. The
25
fact that respondent answered part or all of the request for production is not intended and shall not be
26
construed to be a waiver of all or any part of any objection to any request for production made by
27

28 respondent.

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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 The factual background of this litigation is complex. Respondent will, during the course of
2 this litigation, pursue extensive formal discovery, as well as extensive investigation and informal
3
discovery. The following responses are based upon information presently available to respondent and
4
are made without prejudice to respondents right to utilize subsequently discovered facts and/or
5

6
documents.

7 To the extent that the requests for production purport to require disclosure of confidential

8 attorney-client communications and/or protected work product, respondent objects. No waiver of

9
privilege is intended or should be implied from any of the responses to the request for production.
10
Discovery is continuing and the responding party reserves the right to amend these response
11
at a later date to incorporate later discovered facts and/or documents.
12

13 This general statement is incorporated into each of the responses set forth below.

14 MODIFY THE RESPONSES BELOW TO SUIT YOUR PARTICULAR SITUATION.

15
ALSO ADD OR SUBTRACT THE NUMBER OF RESPONSES AS NEEDED.
16

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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE