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If a request requires the responding party to create nonexistent documents, the responding party may object. A proper objection might include the following language: OBJECTION: This Request seeks a document that does not exist and is therefore not in the possession, custody or control of the responding party.
Generally, a request for production asks the responding party to make available the original documents, but a requesting party may permit photocopies of the requested documents be sent instead, if inspection of the original document is not necessary.
Timeframe for discovery If you are the plaintiff, you can begin discovery 10 days after you serve the first papers in the case or anytime after the defendant files a response. If you are the defendant, you may begin discovery as soon as the case is filed.
A Request for Production (also known as a Demand for Inspection) asks the other side to produce and allow copying or inspection and measuring of a document or thing.
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you can't comply.
Requests for the Production of Documents are used to find all evidence that might be presented at a trial or hearing, or used as evidence in a case. They should include a caption.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. ... The request is vague, ambiguous, or unintelligible. ... The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.
Your response for each request must include either an agreement to comply, a representation of your ability to reply, or an objection to all or part of the request. California Code of Civil Procedure (CCP) §§ 2031.210 et. seq require specific statements in your response.
The following (if applicable) are some grounds for objecting to a request for admission: ? The request is vague or overbroad. ? Attorney-client privilege. ? The request is not relevant to this case.
Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestor's behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information ...