Legal Response Rogs

LEGAL RESPONSE ROGS

This Response to Interrogatories and Requests for Production (the "Responses") is made and served as of Date: by Responding Party: whose principal address is and served to Propounding Party: .

RECITALS

WHEREAS, on Date: the Propounding Party served certain interrogatories and requests for production directed to the Responding Party (the "Requests");

WHEREAS, the Responding Party hereby provides responses, objections, and a privilege log as required by applicable rules of civil procedure and orders of the tribunal; and

WHEREAS, the parties intend that these Responses be a complete, clear, and accurate statement of the Responding Party's present knowledge and documents in its possession, custody, or control as of the date of this document subject to the continuing obligation to supplement.

NOW THEREFORE, in consideration of the foregoing recitals and the mutual covenants contained herein, the Responding Party states as follows:

1. DEFINITIONS

For purposes of these Responses: (a) "Interrogatories" means the written interrogatories served by the Propounding Party; (b) "Requests" means requests for production of documents and tangible things; (c) "Document" or "Documents" is used in the broadest sense and includes all writings, electronic files, records, communications, drafts, and tangible things within the scope of the Requests; and (d) "You" or "Your" means the Responding Party and any representative acting on its behalf.

2. INSTRUCTIONS AND GENERAL OBJECTIONS

2.1 The following general objections are incorporated into each specific response: lack of relevance, overbreadth, undue burden, vagueness, ambiguity, premature, and privileges including attorney-client and work product. The assertion of any objection is not an admission that the information sought is discoverable or admissible.

2.2 Each response is made subject to and without waiving any applicable objection. Information is produced subject to a claim of privilege only where expressly noted and in the privilege log provided below. These Responses are based on present knowledge and documents reasonably available to Responding Party at the time of preparation.

2.3 Responding Party acknowledges a continuing duty to supplement or amend these Responses in accordance with applicable rules if it obtains additional information or documents following the date of this Response.

3. SPECIFIC RESPONSES TO INTERROGATORIES

Interrogatory No. 1. Identify by full name, current or last known employer, job title, and last known business address each person known to the Responding Party who has knowledge of facts relevant to the subject matter of this action.

Objection asserted

Interrogatory No. 2. State the factual basis for Responding Party's position that is the subject of the complaint or defense, including dates, locations, and persons involved.

Objection asserted

Interrogatory No. 3. Identify each document that supports Responding Party's responses to the Interrogatories and state the current location of each document.

Objection asserted

Interrogatory No. 4. State the names of persons who have conducted any investigation referenced in these matters, and summarize the scope of such investigation.

Objection asserted

Interrogatory No. 5. Identify any insurance policies that may provide coverage for the claims or defenses in this action, including insurer name, policy number, and limits.

Objection asserted

4. REQUESTS FOR PRODUCTION — RESPONSES

For each Request for Production, Responding Party states whether documents are produced, withheld, or will be produced subject to a confidentiality agreement. For each produced set of documents, the medium, custodial source, and date range are described below.

Request No. 1. Produce all communications between Responding Party and any third party regarding the subject matter of this action.

Produced Withheld (see privilege log) Will be produced

Request No. 2. Produce all contracts, invoices, or other agreements referenced in Responding Party's defenses.

Produced Withheld (see privilege log) Will be produced

5. PRIVILEGE LOG

The Responding Party withholds certain documents on grounds of privilege or work product protection. The withheld items are described below with sufficient detail to permit a determination of the claim without disclosure of privileged content.

6. CONTINUING OBLIGATION

The Responding Party affirms a continuing obligation to timely supplement these Responses should it discover additional information or documents responsive to the Requests. Any supplement will be provided in writing and served upon the Propounding Party in accordance with applicable rules.

7. CONFIDENTIALITY

To the extent documents contain trade secrets or commercially sensitive information, production is made subject to any protective order in effect. Absent a protective order, the Responding Party may designate documents as confidential and seek appropriate protection from the tribunal.

8. PRESERVATION OF EVIDENCE

The Responding Party certifies that it has taken reasonable steps to preserve documents and electronically stored information potentially relevant to the subject matter of the Requests, including suspension of routine destruction policies as required by law.

9. NOTICES

10. AMENDMENTS; WAIVER

No amendment or waiver of any provision of these Responses shall be effective unless in writing and signed by the party against whom enforcement is sought. A failure to object to any request shall not be deemed a waiver of objections to other requests.

11. GOVERNING LAW

These Responses shall be governed by and construed in accordance with the laws of the State of without regard to conflict of law principles.

12. ENTIRE AGREEMENT

These Responses, including attachments and the privilege log, contain the entire statement of the Responding Party with respect to the matters addressed herein and supersede any prior statements or responses on the same subjects to the extent inconsistent.

13. SEVERABILITY

If any provision of these Responses is held invalid or unenforceable, the remaining provisions shall remain in full force and effect to the fullest extent permitted by law.

14. COUNTERPARTS

These Responses may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument. Facsimile or electronic signatures shall be treated as original signatures for all purposes.

VERIFICATION

I, , declare under penalty of perjury under the laws of the State of that the foregoing Responses are true and correct to the best of my knowledge, information, and belief. Executed on at .

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