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 material produced in response to Civil Investigative Demand Number 13009. 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. Web2. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. 4. They can: IH55J6FL"B]Wsng@i! {.C6. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. 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. 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. 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. Such materials contain the mental impressions, conclusions, opinions, and legal theories of the Government's attorneys in summarizing the Government's understanding of information obtained in the interview, for instance by the emphasis in memoranda of the specific issues of interest to the Division's legal analysis. 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. 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 phrases "CID investigation" and "CID witnesses," because Civil Investigative Demand Number 13009 did not command oral testimony. If an objection is made only to part of a demand, the objectionable section must be specified. 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. Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests or responses thereto to be relevant or material to the subject matter of this action. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? 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. Therefore, there are no "third part[ies]" as that term is defined. The request is irrelevant to the underlying nature of this proceeding. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. Call the civil clerks office of your court to ask when Motion day is. Providing such information in answering this interrogatory would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of providing such information in answering this interrogatory is substantially the same or less for Defendant as for Plaintiff. Your response to this request should be periodically supplemented. A party objecting to a request for production must provide the reasons for the objection. 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. 21. 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. In addition to complying with the provisions of Rules. 3. P. 1.380 applies to all discovery: depositions, admissions, responses to requests to produce, etc. 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. The producing party shall provide any relevant compilations, abstracts, or summaries, either in its custody or reasonably obtainable by it, not prepared in anticipation of litigation. OBJECTIONS. 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. 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. PRODUCING DOCUMENTS OVER OBJECTION. The failure to include any general objection in any specific response does not waive any general objection to that request. 2. Web4.In producing documents requested herein, please produce documents in full, without abridgement, abbreviation or expurgation of any sort. 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. motion to compel production of documents florida. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. To the extent that "during" is intended to mean "at the time of," Plaintiff objects to this definition as overbroad because it would call for materials unrelated to this action. WebSample Objections To Request For Production Of uments that. Indeed, the Court has ordered the parties to disclose the likelihood that they will call those persons as witnesses, and Plaintiff has done so, reducing the list of 184 individuals and entities to 31 individuals whose testimony Plaintiff is very likely or likely to present at trial, either by live testimony or deposition. [CCP 2033.010.] Requests for Production United States District Court Southern District of Florida. 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. Fla. R. Civ. WebFLORIDA RULE OF CIVIL PROCEDURE 1.380: The language of Fla. R. Civ. 3. Secure .gov websites use HTTPS Responses to Interrogatories and Requests for Production of Documents 2. 6. Please produce any and all correspondence, memoranda, reports, written notes, diagrams, charts or other similar documents which relate to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Sunny Balwani Sentenced Is This the Final Theranos Chapter. 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. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best 6. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. P. 1.350 (b) (amended eff 10/28/21). 3 to refer to "Civil Investigative Demand No. Going through discovery is a bit like navigating a minefield. An official website of the United States government. 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. Please keep this in mind if you use this service for this website. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. WebIt is your agreed own times to action reviewing habit. 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. An official website of the United States government. in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. 5. 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. 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 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. For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. If the court issues an order compelling production and the responding party still fails to reply, that party may be held in contempt of court and may face sanctions up to and including the dismissal of pleadings. we will unquestionably offer. 89 0 obj <>stream REQUEST NO. Webto Complaint Counsels First Request for Production of Documents to Respondents (Request) issued on November 5, 2002. 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. If you do not object to a request, those Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. Web4. Copy of marriage certificate if a derivative claim is being made for loss of consortium, loss of service, or any other claim by your spouse as a result of personal 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. Fla. R. Civ. Documents already produced will not be produced again. PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECONDREQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. 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 further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. These interviews were conducted by attorneys and staff of Plaintiff. 8. 4. 22. 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. 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. The responsive material includes teeth, shade guides, a video tape and a CD-ROM.Alternatively, Plaintiff will produce copies of the documents, except the teeth, the shade guides, the videotape, and the CD-ROM, all of which will be available for inspection at Plaintiff's offices. 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. If a deponent fail s to answer a question propounded or submitted under rule 1. 1. 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. A .gov website belongs to an official government organization in the United States. 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. 1. hb```f``b`a``d`@ +P w>f^k?sd`lRj'H$LxGh@4$~i~ :' SLzL'rb[g00m*".qLy~@_ 7< 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. Without waiving this objection and to the extend I understand this question, a copy of a citation for failure to yield dated January 31, 2014, is provided with these responses. Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. All copies of discovery requests served upon third parties in connection with the DOJ's CID investigation of Dentsply. Plaintiff objects to Instruction No. endstream endobj 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. 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. 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. A specific response may repeat a general objection for emphasis or some other reason. 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. Such a reading here demonstrates the problems with the use of this undefined term. 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. WebREQUESTS FOR PRODUCTION 1. 1. Therefore, there are no "statements" as that term is defined. Responding to such requests would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of responding to such requests is substantially the same or less for Defendant as for Plaintiff. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. 125 0 obj <]/Info 118 0 R/Filter/FlateDecode/W[1 2 1]/Index[119 13]/DecodeParms<>/Size 132/Prev 24054/Type/XRef>>stream documents, tapes and records they have about your case. While "CID" is defined to refer to "Civil Investigative Demand No. You will likely be asked to provide a long list of answers and fetch a lot of documents. 2. 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. 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). 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). 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. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best 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. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ The documents containing, including, or derived from "any verbatim statement of a third party" would include all documents created by Plaintiff in the course of the investigation preceding this case that touch explicitly or implicitly on any factual matter. 7. "Verbatim statements of a third party" include, but are not limited to, transcripts of the depositions of third parties, oral statements from any third party or its counsel, and correspondence from third parties to Plaintiff. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. Civil Investigative Demand Number 13009 was not an investigation, it was a document request. Plaintiff objects to Definition No. Share sensitive information only on official, secure websites. 5. WebIn litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. All such documents and information will not be produced. Contact us today for a free consultation. 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. 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. If an objection is made to part of an item or category, the part must be specified. 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. 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. 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. 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. %PDF-1.5 % A party should, without having to be asked, promptly produce any responsive documents discovered after the original production. 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. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. 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. Plaintiff, by and through its attorneys, and pursuant to Rules 33 and 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") Second Request for Documents and First Set of Interrogatories as follows: 1. To the extent any of Defendant's document requests or its interrogatory seek documents or answers that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests and interrogatory as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, 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. Plaintiff objects to Instruction No. entities owning the property where the plaintiff was injured, as described in the Complaint. Fla. R. Civ. 2. A response to a document request or interrogatory stating that objections and/or indicating that documents will be produced shall not be deemed or construed that there are, in fact, responsive documents, that Plaintiff performed any of the acts described in the document request, interrogatory, or definitions and/or instructions applicable to the document request or interrogatory, or that Plaintiff acquiesces in the characterization of the conduct or activities contained in the document request, interrogatory, or definitions and/or instructions applicable to the document request or interrogatory. Furthermore, attorneys are reminded that evasive or incomplete disclosures, answers, or responses may be sanctionable under the provisions of. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. A question propounded or submitted under RULE 1 irrelevant to the work product doctrine full, having... 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