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(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).
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.
You must respond to the request and swear under oath that your response is true. Then you'll deliver your response to the other side's attorney (or to the other side, if they don't have an attorney).
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.?
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.
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).
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.
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.