[Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Party's Name] [Opposing Party's Address] [City, State, ZIP] Re: Responses to Request for Production of Documents Dear [Opposing Party's Name], I hope this letter finds you well. I am writing to provide you with the requested responses to your Request for Production of Documents dated [date of request], pursuant to the [relevant court rule/code] in the state of Georgia. As per your request, I have organized the responses into different categories for your convenience. Please find them outlined below: [Paragraph 1: Introduction] In this paragraph, briefly introduce the purpose of the letter and acknowledge the receipt of the request for production of documents. Mention the date and number of the request. [Paragraph 2: General Objections] In this paragraph, address any general objections to the request for production of documents. Clearly state any objections based on relevance, privilege, undue burden, or over breadth. Ensure to cite the specific court rules or codes supporting your objections. [Paragraph 3-n: Document Category Responses] In these paragraphs, address each category of documents requested separately. Provide a clear and detailed response to each category, including any corresponding objections, if applicable. For instance: a) Category 1: Contracts and Agreements Provide a list of all contracts and agreements responsive to your request. If any documents are being withheld, provide a privilege log outlining the basis of withholding. b) Category 2: Financial Statements Include copies of relevant financial statements for the requested time period. If certain statements are being withheld, provide a privilege log or state the basis for withholding. [Continue with additional paragraphs for each category as necessary] [Paragraph n+1: Conclusion] In this paragraph, conclude the letter by reiterating your commitment to cooperating in the discovery process and providing the requested documents to the extent possible. Additionally, specify a reasonable timeline for the production of documents. Finally, please note that the responses provided herein are without prejudice to any further rights and objections that may be raised during the course of this litigation. If you have any questions or need further clarification regarding the responses provided, please do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. I am available to discuss this matter further and work towards a mutually beneficial resolution. Thank you for your attention to this matter, and I look forward to your prompt response. Sincerely, [Your Name] [Your Title or Position] [Your Law Firm (if applicable)]
Georgia Sample Letter for conveying Responses to Request for Production of Documents
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How to fill out Georgia Sample Letter For Conveying Responses To Request For Production Of Documents?
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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.
