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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
1 PROPOUNDING PARTY: Any Plaintiff
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RESPONDING PARTY: Any Defendant
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SET NUMBER: One
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TO _______________AND THEIR COUNSEL OF RECORD:
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6 Pursuant to the provisions of Federal Rules of Civil Procedure 26 and 34, ___________herein
7 responds and objects as follows to the Requests for Production of Documents, Set One propounded
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by ___________.
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Dated________________ _______________________________________________
11 ANY ATTORNEY OR PARTY
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General Statement
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These responses are made solely for the purposes of this action. Each answer is subject to
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15 all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all
16 other objections and grounds which would require the exclusion of any document herein if the
17 request for production, or any documents contained herein were made by, a witness present and
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testifying in court, all of which objections and grounds are reserved and may be interposed at the
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time of trial.
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Except for explicit facts admitted herein, no answer or implied admissions are intended
22 hereby. The fact that respondent answered any request for production shall not be taken as an
23 admission that respondent accepts certain events or admits the existence of any fact set forth or
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assumed by such request for production, or that such response constitutes admissible evidence. The
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fact that respondent answered part or all of the request for production is not intended and shall not be
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construed to be a waiver of all or any part of any objection to any request for production made by
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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
1 The factual background of this litigation is complex. Respondent will, during the course of
2 this litigation, pursue extensive formal discovery, as well as extensive investigation and informal
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discovery. The following responses are based upon information presently available to respondent and
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are made without prejudice to respondents right to utilize subsequently discovered facts and/or
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documents.
7 To the extent that the requests for production purport to require disclosure of confidential
13 This general statement is incorporated into each of the responses set forth below.
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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE