Fill and Sign the Craig V City of Mobilecivil Action No 18 Form

IN THE CIRCUIT COURT OF ________COUNTY, ALABAMA _______________, and *_________________,**Plaintiffs,**vs. *CIVIL ACTION NO.:*____________________ *CV-_________________________ et al., **Defendants.*PLAINTIFFS= OBJECTIONS TO THE DOCUMENT REQUESTS IN DEFENDANT= S NOTICES OF PLAINTIFFS= DEPOSITIONS COME NOW Plaintiffs, by and through counsel, and make the following objections to the certain document requests included within Defendant, _________________, Notices of Depositions:1.Plaintiffs generally object to each document request which includes the word Aall@. Plaintiffs may not have Aall@ documents within a certain category, and some are privileged and/or confidential under the attorney client privilege and/or the work product doctrine.2.Plaintiffs specifically object to Requests 1, 2, 3, 9, 10, 13, 14, 15, 17, 18, and 19in the Notice for ______________, and Requests 1, 2, 3, 8, 9, 12, 13, 15, 16, and 17 in the Notice for ____________.3.Plaintiffs object to the above requests to the extent they seek documents which areirrelevant and immaterial to the ______________________________________________claims made in their Complaint, and /or request documents too numerous, unduly burdensome, and voluminous. JOHN DOE & ASSOCIATES, P.C.Attorneys for PlaintiffsPost Office Drawer ____Mobile, Alabama _____(334) ________BY:________________________________Plaintiff=s attorneyAttorney=s numberCERTIFICATE OF SERVICEI do hereby certify that I have on this _____ day of July,1999, served a copy of the foregoing pleading by mailing same by United States mail, properly addressed and first class postage prepaid, to the following:Defense counsel____________________________________Plaintiff=s counsel