Legal Response ROG

LEGAL RESPONSE ROG

Responding Party:     Requesting Party:

Court:     Case No.:     Date Served:

RECITALS

WHEREAS, on the date indicated above, Requesting Party served upon Responding Party a set of written interrogatories pursuant to applicable rules of civil procedure; and

WHEREAS, Responding Party supplies the following responses and objections to the propounded interrogatories and seeks to preserve all applicable privileges and protections; and

WHEREAS, the parties desire to record Responding Party's formal answers, objections, and certifications to the interrogatories identified below.

NOW THEREFORE, Responding Party answers and objects as follows.

1. DEFINITIONS

For purposes of these responses: words in singular include the plural and vice versa; "Document" means any writing, recording, photograph, electronically stored information, or tangible thing; "You" and "Your" refer to Responding Party and its agents, representatives, insurers and attorneys. Terms not defined herein shall be given their plain and ordinary meaning.

2. INSTRUCTIONS AND SCOPE

The following responses are made subject to the instructions and definitions above. Responses are provided based on information known or reasonably available to Responding Party at the time of service and are made without prejudice to Responding Party's right to supplement or amend pursuant to applicable rules.

3. GENERAL OBJECTIONS

Responding Party objects to each interrogatory to the extent it seeks information protected by the attorney-client privilege, work product doctrine, or any other applicable privilege or immunity. Responding Party also objects to requests that are vague, ambiguous, overbroad, unduly burdensome, not reasonably calculated to lead to admissible evidence, or that seek discovery beyond the permissible scope. These objections are made without waiver of the right to assert additional objections as may become appropriate.

4. SPECIFIC RESPONSES TO INTERROGATORIES

The following responses are made to the numbered interrogatories as propounded. Each response is given subject to the foregoing objections and instructions.

5. DOCUMENTS AND PRODUCTION

Where these responses refer to documents, responsive documents will be produced subject to appropriate protections and in the form in which they are kept in the ordinary course of business. Documents withheld on the basis of privilege or protection will be identified by privilege log if required by applicable rules.

6. RESERVATION OF RIGHTS

Responding Party expressly reserves the right to amend, supplement or modify these responses and to assert additional objections, privileges or protections as discovery progresses or additional facts are learned.

7. CERTIFICATE OF SERVICE

I certify that on the date indicated below, a true and correct copy of these responses and objections was served on the individual(s) listed below by the method(s) indicated.

Hand Delivery    U.S. Mail    Email    Electronic Filing    Facsimile

8. SUPPLEMENTATION

Responding Party acknowledges the continuing duty to supplement or correct these responses if additional discoverable information is identified in accordance with applicable rules.

9. NOTICES

All notices required or permitted under these responses shall be in writing and shall be delivered to the addresses provided below or to such other address as a party may designate in writing.

10. GOVERNING LAW; MISCELLANEOUS

These responses shall be governed by the laws and rules of the jurisdiction in which the above-captioned action is pending. The headings contained in this document are for convenience only and shall not affect the interpretation of any provision.

Entire Agreement: These responses, together with any written objections and documents produced contemporaneously, constitute the entire written record of Responding Party's responses to the specified interrogatories and supersede any prior oral or written communications on the same subject.

Severability: If any provision of these responses is held to be invalid or unenforceable, the remainder of these responses shall remain in full force and effect.

Amendments and Waiver: No amendment or waiver of any provision of these responses shall be effective unless in writing and signed by the party to be charged.

VERIFICATION

I, the undersigned, declare under penalty of perjury under the laws of the applicable jurisdiction that I have read the foregoing responses and that the facts stated herein are true and correct to the best of my knowledge, information and belief.

Declarant Name:

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