Legal Answers to RFAs

LEGAL ANSWERS TO REQUESTS FOR ADMISSION

This instrument constitutes the Answers and Objections to Requests for Admission served in the action captioned Case Number: arising between Requesting Party Name: (hereinafter "Requesting Party") and Responding Party Name: . Requests for Admission were served on: Month Day Year .

RECITALS

WHEREAS, Requesting Party served written Requests for Admission directed to Responding Party in accordance with applicable rules of civil procedure; and

WHEREAS, Responding Party submits these Answers and Objections in good faith, subject to the objections and reservations set forth herein, and without waiver of any rights to seek additional discovery or to supplement these responses as permitted by law; and

WHEREAS, the parties intend these Answers and Objections to be used in the above-captioned litigation only and not as admissions in other proceedings except as required by law;

NOW THEREFORE, Responding Party responds to the Requests for Admission as follows:

DEFINITIONS

For purposes of these Answers and Objections, the following definitions apply: "Document" means any written, recorded, or graphic material as defined by the rules of civil procedure; "Identify" means to state name, present or last known business address, and business or occupation; and terms defined in the Requests shall have the same meaning where applicable. These definitions are incorporated into each response.

GENERAL OBJECTIONS

Responding Party makes the following general objections to each and every request: (a) objections to the extent Requests exceed the scope of permissible discovery; (b) objections to vagueness, ambiguity and undefined terms as used without limiting meanings stated herein; (c) objections to burdensomeness and overbreadth to the extent compliance would produce privileged or work product materials; and (d) objections to the extent Requests seek information protected by attorney-client privilege, work product doctrine, confidentiality agreements, or other applicable privileges or protections. These objections are continuing and are not waived by any partial or complete answer.

INSTRUCTIONS

Each request is answered separately and fully to the extent information is known or readily obtainable after reasonable inquiry. Where Responding Party lacks sufficient information to admit or deny a request, the response states that inability together with the efforts made to obtain the information. Responses are subject to supplementation.

SPECIFIC ANSWERS TO REQUESTS FOR ADMISSION

For each Request for Admission propounded, Responding Party sets forth below: (1) the request number; (2) the request as written; (3) the response (Admit, Deny, Qualified Admission, or Objection); and (4) a concise explanation where necessary. If Responding Party asserts an objection to a request, the objection and the specific ground for the objection are stated.

If additional Requests were propounded beyond those set forth above, Responding Party attaches Additional Responses on separate pages and incorporates them herein by reference. Any admission is limited to the exact scope of the request and does not constitute an admission for any other purpose.

RESERVATION OF RIGHTS

Responding Party reserves the right to supplement or amend these Answers and Objections in the event additional facts are discovered, to assert further objections, and to produce or withhold documents subject to claims of privilege or protection as permitted by law.

AUTHENTICATION AND DOCUMENT PRODUCTION

Where a response refers to documents, Responding Party will identify the documents by production number or Bates range to the extent practicable. Responding Party objects to requests that seek the production of documents protected by privilege; to the extent privileged material is inadvertently produced, Responding Party asserts the protections of the rules governing inadvertent disclosure.

NOTICES

Any notices required or permitted by these Answers shall be delivered to the addresses set forth below or to counsel of record for each party.

AMENDMENTS AND WAIVER

These Answers and Objections may be amended or supplemented to correct errors or to add responses discovered after reasonable inquiry. No waiver of any right, claim, or objection is effective unless in writing and signed by the party making the waiver.

GOVERNING LAW

These Answers and Objections shall be governed by and construed in accordance with the laws applicable to the underlying litigation, including the rules of civil procedure applicable in the forum in which the action is pending.

ENTIRE AGREEMENT; SEVERABILITY

These Answers and Objections contain the entire statement of Responding Party's positions with respect to the Requests for Admission and supersede all prior oral or written statements to the extent they relate thereto. If any provision is held invalid, the remaining provisions shall remain in full force and effect.

VERIFICATION

I declare under penalty of perjury under the laws of the jurisdiction in which this action is pending that the foregoing Answers and Objections are true and correct to the best of my knowledge, information and belief, after reasonable inquiry.

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