[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP] Re: [Case Name and Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. In response to your Request for Production of Documents dated [Date], we hereby provide our detailed responses and accompanying documents as requested. Please note that these responses are provided pursuant to the California Civil Discovery Act and are subject to our objections as stated below. Response to Request Number 1: [Specify Request Number] We object to this request on the grounds that it is overly broad and unduly burdensome. However, in the spirit of cooperation, we are providing the following documents [Describe the documents in detail]. Response to Request Number 2: [Specify Request Number] We object to this request based on attorney-client privilege, work product doctrine, and privacy concerns. We will not be producing any documents in response to this request. Response to Request Number 3: [Specify Request Number] We object to this request as it seeks information or documents that are irrelevant to the issues in this case and not reasonably calculated to lead to admissible evidence. No documents will be produced for this request. Response to Request Number 4: [Specify Request Number] We object to this request as it seeks confidential and proprietary trade secrets and sensitive business information. Accordingly, no documents will be produced in response to this request. Please note that our objections are without prejudice to our right to produce documents at a later time, should the Court rule otherwise. Furthermore, we request that you produce any and all documents responsive to our prior requests and provide a privilege log for any withheld or redacted documents, if applicable. Finally, as is customary under the California Code of Civil Procedure, we reserve the right to supplement or modify these responses should any additional documents come to our attention or the circumstances change. Please confirm receipt of this response letter and provide any further clarification if necessary. Should you have any questions, do not hesitate to contact me at [Your Phone Number] or [Your Email Address]. Thank you for your attention to this matter. Sincerely, [Your Name] [Your Law Firm] [Your Law Firm's Address] [City, State, ZIP]