Legal Responses to ROGs

Legal Responses to ROGs

This document constitutes the Responses to Interrogatories (the "Responses") served by Responding Party: to Propounding Party: in the matter captioned Case Name: , Case Number: , pending in Court: . Date of Service: .

RECITALS

WHEREAS, the Propounding Party served written Interrogatories pursuant to the applicable rules of civil procedure seeking information, documents, and admissions relevant to the subject matter of this litigation; and

WHEREAS, the Responding Party asserts certain objections on grounds including relevance, privilege, overbreadth, vagueness, undue burden, and confidentiality, but provides responsive information subject to and without waiving those objections; and

WHEREAS, these Responses are made in an effort to provide substantive answers while preserving all rights and objections as set forth herein.

NOW THEREFORE

NOW THEREFORE, in consideration of the foregoing recitals and the mutual obligations set forth below, Responding Party furnishes the following responses and objections to the Interrogatories propounded by Propounding Party.

1. DEFINITIONS AND INSTRUCTIONS

1.1 Definitions. As used herein, the following terms have the meanings set forth: "Document" or "Documents" means all writings, recordings and tangible things as defined by the applicable rules of civil procedure; "Identify" when used with respect to a person means to state the person's full name, present or last known business and home address and telephone number, and the person's relationship to the parties.

1.2 Interpretation. These definitions and instructions are incorporated into each response. Words in the singular include the plural and vice versa. The terms "and" and "or" shall be construed conjunctively and disjunctively as necessary to bring within the scope of any request any information that might otherwise be construed to be outside its scope.

2. GENERAL OBJECTIONS

2.1 Responding Party objects to each Interrogatory to the extent it seeks information protected by the attorney-client privilege, attorney work product doctrine, common interest doctrine, or any other applicable privilege or immunity. To the extent privileged material is identified, Responding Party will provide a privilege log in accordance with Section 5 of these Responses.

2.2 Responding Party objects to each Interrogatory to the extent it is vague, ambiguous, overly broad, unduly burdensome, or not reasonably calculated to lead to admissible evidence. Subject to, and without waiving, these objections, Responding Party answers the Interrogatories to the fullest extent possible.

2.3 No inference of waiver. The provision of information or documents, whether voluntarily or in response to a specific Interrogatory, shall not be construed as an admission of relevance or admissibility, and Responding Party does not waive any objections by producing or describing such information.

3. SPECIFIC RESPONSES TO INTERROGATORIES

The following are Responding Party's specific responses to the numbered Interrogatories. Where an objection is asserted as to any Interrogatory, the basis for the objection is stated and, to the extent possible, a response is provided.

If an Interrogatory calls for information that is not known, Responding Party so states and provides the best information available after a reasonably diligent inquiry.

4. PRIVILEGE AND CONFIDENTIALITY

4.1 Privilege Assertions. Where documents or communications are withheld on claim of privilege or protection, Responding Party will provide a privilege log identifying for each withheld document: (a) a sequential log number; (b) date; (c) author(s); (d) recipient(s); (e) general description of the document sufficient to assess the claim of privilege; and (f) the privilege or protection asserted.

4.2 Confidential Information. Responsive information that is confidential shall be designated as such and produced subject to any protective order or by agreement of the parties. Designation of confidentiality does not waive objections or privileges.

5. CONTINUING OBLIGATION TO SUPPLEMENT

Responding Party has a continuing duty to supplement or amend these Responses should additional information become known that renders these Responses incomplete or inaccurate. Supplements will be provided as required by the rules of civil procedure.

6. RESERVATION OF RIGHTS

By responding, Responding Party does not waive any objections, defenses, or privileges, nor is Responding Party precluded from asserting additional objections or privileges with respect to any future discovery requests or use of information at hearing or trial.

7. NOTICES

8. AMENDMENT, WAIVER, SEVERABILITY

8.1 Amendment. These Responses may be amended or supplemented by written instrument signed by Responding Party or counsel where required by applicable rules.

8.2 Waiver. No waiver of any provision of these Responses shall be effective unless in writing and signed by the party waiving compliance.

8.3 Severability. If any provision of these Responses is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

9. GOVERNING LAW; ENTIRE AGREEMENT

These Responses shall be interpreted and enforced in accordance with the laws of the State of . These Responses contain the entire understanding regarding the subject matter herein and supersede any prior understandings.

10. VERIFICATION

I, the undersigned, declare under penalty of perjury under the laws of the State of that I am authorized to make these Responses on behalf of Responding Party; that I have read the foregoing Responses and know the contents thereof; and that the statements contained therein are true and correct to the best of my knowledge and belief.

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