Legal Answers and Production Document

LEGAL ANSWERS AND PRODUCTION DOCUMENT

Court:    Case No.:

Plaintiff Name:    Defendant Name:

RECITALS

WHEREAS, the Parties are engaged in litigation in the above-captioned matter and Plaintiff has propounded written interrogatories and requests for production of documents to Defendant; and

WHEREAS, these Legal Answers and Production Document set forth Defendant's substantive answers to interrogatories and identify the categories of documents Defendant will produce, subject to the objections, qualifications and privileges asserted herein; and

WHEREAS, the Parties intend for these Answers and this Production to be binding and to comply with applicable rules of civil procedure governing discovery.

NOW THEREFORE

In consideration of the foregoing recitals and the mutual covenants contained herein, Defendant responds to the interrogatories and production requests as follows. These responses are made in good faith based on information reasonably available to Defendant at the time of execution and are subject to the stated objections and qualifications below.

1. DEFINITIONS

For purposes of these Answers and any production, the following definitions apply: "Document" means every writing, record, photograph, sound or video recording, electronic file, email, memorandum, note, calendar entry, database extract, metadata and any tangible thing within the scope of discovery. "You" and "Your" mean the responding party identified above. "Identify" when used with respect to a person shall mean to give the person's full name, last known address and telephone number and to identify the person's relationship to the responding party.

2. GENERAL OBJECTIONS

Defendant objects to each Interrogatory and Request for Production to the extent it seeks information protected by the attorney-client privilege, work-product doctrine, common-interest doctrine, other applicable privileges or protections, or to the extent it seeks information that is not relevant to the claims or defenses in the litigation or is unreasonably cumulative, duplicative, overly broad, unduly burdensome, or disproportionate to the needs of the case.

These objections are ongoing and are preserved for trial and any other proceeding. Subject to and without waiver of the foregoing objections, Defendant provides the following answers and will produce responsive, non-privileged documents as described below.

3. SPECIFIC ANSWERS TO INTERROGATORIES

Interrogatory No. 1: Identify each person known to you who has knowledge of facts relevant to the claims or defenses in this litigation and state the subject matter of that knowledge.

Interrogatory No. 2: Describe in detail the factual basis for Defendant's denials and affirmative defenses.

Interrogatory No. 3: Identify all documents on which you rely or intend to rely at trial or in support of any claim or defense.

4. PRODUCTION OF DOCUMENTS

Defendant will produce non-privileged, responsive documents in its possession, custody or control as identified in the categories below. Productions will be made in the order and manner described herein, subject to reasonable limitations for burden and proportionality.

Production Date Range: From to

Categories of Documents to be Produced

Emails and attachments relevant to the subject matter.

Contracts, agreements, amendments and related correspondence.

Financial records, invoices, billing statements and payment records.

Other:

For each produced document that is part of a larger file or thread, Defendant will produce reasonably available attachments and earlier versions where such material is responsive and not privileged.

5. ELECTRONICALLY STORED INFORMATION (ESI)

Defendant will produce ESI in the following preferred formats (select one or more). Native format means the file is produced in its original application format and includes associated metadata where reasonable and available.

PDF with searchable text

Native format with associated metadata

TIFF images with load files and text files

6. PRIVILEGE, REDACTION, AND PRIVILEGE LOG

Documents withheld or redacted on the basis of privilege or protection will be identified on a privilege log that describes, to the extent consistent with applicable law, the document type, general subject matter, author(s), recipient(s), date, and the basis for the privilege. Production of a privilege log is without waiver of any privilege or protection.

Privilege log to be provided by:

Privilege Log Entries (summary)

7. CERTIFICATION

I certify under penalty of perjury under the laws of the applicable jurisdiction that the foregoing answers and the documents produced are true and correct to the best of my knowledge, information and belief after reasonable inquiry, and that all responsive, non-privileged documents in the responding party's possession, custody or control have been produced or identified as specified herein.

8. PRESERVATION OF EVIDENCE

Defendant affirms that it has undertaken reasonable and proportionate steps to preserve relevant documents and electronically stored information, including instituting a litigation hold to preserve relevant custodial and non-custodial sources of potentially relevant information.

9. NOTICES

10. AMENDMENTS; WAIVER; COUNTERPARTS

These Answers and Production may be amended or supplemented if additional information becomes available. No waiver of any provision of these Answers shall be effective unless in writing and signed by the party waiving the provision. This document may be executed in counterparts, each of which shall be deemed an original.

11. GOVERNING LAW; ENTIRE AGREEMENT; SEVERABILITY

This document shall be governed by the laws of the jurisdiction in which the court identified above sits, without regard to conflict of law principles. These Answers and Production constitute the entire agreement between the Parties with respect to the subject matter hereof and supersede any prior statements or agreements on the same subject. If any provision of this document is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

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