This form is a sample plaintiff's response to the defendant's first request for the production of certain documents in a personal injury action.
Virginia Plaintiff's Response to Defendant's First Request for Production of Documents - Personal injury
State:
Multi-State
Control #:
US-PI-0191
Format:
Word;
Rich Text
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How to fill out Plaintiff's Response To Defendant's First Request For Production Of Documents - Personal Injury?
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FAQ
Court rules usually limit the number of questions included in an interrogatory. For example, under Rule 33 of the Federal Rules of Civil Procedure, each party may only ask the other party 25 interrogatory questions, unless the court permits them to ask more.
Check or type: ?I will allow this request in whole and will provide the documents or things as requested.? Check or type: "I cannot comply with the request because no such documents or things exist. A diligent search and reasonable inquiry have been made in an attempt to comply with this demand.?
Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery or to the claim or defense of any other party, including the existence, description, nature, custody, ...
In Virginia, you can ask 30 interrogatories. Usually, Requests for Production of Documents go hand-in-hand with interrogatories, because we use them to request the documents that back up the information provided in the interrogatories. If we're curious about income, we'll ask for pay stubs and income tax returns.
If the court grants your attorney's motion to compel discovery, the other party must comply with the judge's order and supply the requested materials within any deadline specified. If they fail to do so, sanctions can be issued in varying levels of severity depending on how egregious their noncompliance was.
No party shall serve upon any other party, at any one time or cumulatively, more than thirty written interrogatories, including all parts and sub-parts without leave of court for good cause shown.
You can use interrogatories to find out facts about a case but they cannot be used for questions that draw a legal conclusion.
Generally, interrogatories are objectionable if they seek information that is not within the scope of discovery as defined in Maryland Rule 402 or Federal Rule 26(b). These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. or protected by the work product doctrine.