Georgia Sample Letter for conveying Responses to Request for Production of Documents
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FAQ
Your response must be given under oath and should include the following language at the end of the document, above a line with the date and your signature: ?I declare under penalty of perjury under the laws of the State of California that the forgoing answers are true and correct.?
I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
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.
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.
Definition: A written list of documents, electronic files, and audio and video recordings or physical things, submitted to a party from his or her adversary to inspect and copy the requested items and that have relevance to the issues in a lawsuit.
For example, if the other party asks you to produce ?any and all records from your bank account,? you may want to object, as this request is overly broad, and it is unduly burdensome for you to locate and produce every document you have ever received from your bank since you opened the account.
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.
