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The issues discussed above in connection with interrogatories are also the issues which you need to cover in your requests for production. However, because requests for production do not yield a written answer, you can ask both for specific documents and for general categories of documents.
2033.210. (a) The party to whom requests for admission have been directed shall respond in writing under oath separately to each request. (b) Each response shall answer the substance of the requested admission, or set forth an objection to the particular request.
When responding to Requests for Admissions, remember to answer as follows: Admit: If any portion of the Request for Admission is true then you must admit to that portion of the request. You are also allowed to have a hybrid response admit the part of the request that is true while denying another part.
The plaintiff must respond to your requests for discovery. The plaintiff must respond by the deadline. There are different ways to make sure you get each kind of discovery if the plaintiff does not give it to you by the deadline.
The making available by a party of documents in his possession, custody or power for inspection by the other party or for use as evidence at trial.
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A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.