Legal Response to Request

LEGAL RESPONSE TO REQUEST

This Legal Response to Request is submitted by Respondent: and is directed to Requesting Party: concerning Case/File Number: . Response Date: .

RECITALS

WHEREAS, Requesting Party served one or more written requests for documents, information, or admission (collectively, the "Requests") upon Respondent pursuant to the applicable rules and procedures governing discovery and disclosure; and

WHEREAS, Respondent has conducted a reasonable inquiry and search for responsive records and has determined the scope and nature of information available and objections applicable to particular Requests; and

WHEREAS, the parties desire to set forth Respondent's formal responses, objections, and production status with specificity and in a manner intended to preserve privileges and other protections.

NOW, THEREFORE

In consideration of the foregoing recitals and the mutual promises contained herein, Respondent hereby delivers the following responses and objections to the Requests.

DEFINITIONS

For purposes of these responses, the following definitions apply unless otherwise indicated: "Document" means all written, recorded or graphic material, irrespective of form; "Communication" includes transmittal of information by any means; "Identify" with respect to a person means to provide full legal name, last known business address, and relationship to the parties.

GENERAL OBJECTIONS

Respondent incorporates the following general objections to each Request: (a) Respondent objects to any request to the extent it seeks information protected by attorney-client privilege, work product doctrine, or other applicable privilege; (b) Respondent objects to any request that is vague, ambiguous, overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence; (c) Respondent objects to requests seeking information beyond the scope or time period relevant to the action; (d) These general objections are continuing and supplemental and are not waived by any specific response or production.

SPECIFIC RESPONSES

The numbered entries below correspond to the numbered Requests served by Requesting Party. Each entry states the Request number, any specific objections, and the substantive response. Where documents are produced, the production identifier or Bates range is provided. These responses are given without waiver of any objection.

Request No. — Request (summary):

Claim of privilege Overbroad/unduly burdensome Not relevant

Request No. — Request (summary):

Claim of privilege Overbroad/unduly burdensome Not relevant

Request No. — Request (summary):

Claim of privilege Overbroad/unduly burdensome Not relevant

DOCUMENT PRODUCTION

Documents identified as responsive are produced subject to the below descriptions. Unless otherwise indicated, documents are produced in the manner maintained in the ordinary course of business and may include redactions made to protect privilege or confidential information.

RESERVATION OF RIGHTS

Respondent expressly reserves the right to amend, supplement, correct, or clarify these responses and to rely upon any objections or privileges asserted herein. Production of documents is not an admission that any document is relevant, admissible, or authentic.

CERTIFICATION

I certify that I have read these responses and that, to the best of my knowledge after reasonable inquiry, the responses are true and correct and that documents produced are those reasonably located following a diligent search.

MISCELLANEOUS PROVISIONS

Governing Law: The interpretation and enforcement of these responses shall be governed by the substantive law specified in the operative case or agreement. Entire Agreement: These responses, together with any written agreements identified herein, constitute the full and complete statement of Respondent's position as to the Requests. Severability: If any provision hereof is held invalid, the remainder shall remain effective. Notices: Notices shall be provided in writing to the addresses used in the case record or as subsequently provided in writing. Amendments and Waiver: Any amendment or waiver must be in writing and signed by the party against whom enforcement is sought. Counterparts: This document may be executed in counterparts and by electronic or facsimile signature, which together shall be deemed one instrument.

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