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For Federal Court, you want to look at the Federal Rules of Civil Procedure, particularly rules 33 and 34. Doc requests don't require verifications, and you serve only objections, you don't need verifications for interrogatory responses.
CCP §§ 2031.210-2031.240. If all of the RFPs are not produced based solely on legal objections, the requests for production do not need to be verified. CCP § 2031.250. A party can not avoid complying based on burdensome objections.
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 admission are used to ask another party to admit that certain facts are true, or that certain documents are authentic. If admitted as true or authentic, these facts and documents do not need to be proven or authenticated at trial.
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.
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).
How to Request Production of Documents and Things Download the template for Request for Production. ... Fill out basic information at the top. ... Choose a location for the other side to bring the documents. ... Add your own definitions (if useful) ... Write your requests for production. ... Sign and date the document. ... Make copies.
(CCP § 2031.240). Unless your written response includes only objections without any factual assertions, it must be verified. This means it must include a statement under the penalty of perjury that your response is true and correct. (CCP § 2031.250).