Legal Responses to RPDs

LEGAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS

Court:   Case No.:

Plaintiff:   Defendant:

Responding Party:

Requests for Production were served on: , .

RECITALS

WHEREAS, the party identified above has been served with written Requests for Production of Documents, set forth in the instrument captioned Requests for Production served in this action; and

WHEREAS, the responding party asserts the right to preserve objections and privileges while providing responsive documents to the extent required by applicable rules; and

WHEREAS, these Responses set forth the responding party's specific answers, objections, and production protocols with respect to each numbered request served.

NOW THEREFORE, the responding party responds to the Requests for Production as follows:

1. DEFINITIONS

For purposes of these Responses, the following definitions apply. Terms not defined herein have their plain and ordinary meanings. "Document" and "Documents" mean all writings, records, electronic files, metadata, emails, attachments, calendars, notes, reports, sound and image files, and any other tangible or intangible things within the meaning of the applicable rules of civil procedure.

2. GENERAL OBJECTIONS

The responding party objects to each Request for Production to the extent that it seeks information protected by the attorney-client privilege, attorney work product doctrine, privacy protections, trade secret protections, or any other applicable privilege or immunity. The responding party also objects to each request to the extent it is overbroad, unduly burdensome, vague, ambiguous, seeks information not relevant to the claims or defenses in this action, or seeks documents that are not within the responding party's possession, custody, or control. These objections are intended to be specific where appropriate and are not exhaustive; the responding party expressly preserves all objections and defenses.

Without waiving these objections, the responding party will produce non-privileged, responsive documents as described in Section 4 below and will provide a privilege log for any withheld materials.

3. PRODUCTION PROTOCOLS

Documents will be produced in electronic image format (PDF or TIFF) with readily accessible text (OCR) and associated metadata where available, except for native files where production in native format is reasonably required. Production will include Bates numbering and a cover letter identifying the producing custodian and date range.

Custodians searched:

Date range for search: From , to , .

4. SPECIFIC RESPONSES

Each numbered response below corresponds to the numbered Request for Production propounded by the requesting party. Responses are provided subject to the General Objections set forth above and without waiver of any objections as to competency, relevance, materiality, privilege, or admissibility.

Request No. 1

Documents Produced:   Withheld on grounds of privilege:

Request No. 2

Documents Produced:   Withheld on grounds of privilege:

Request No. 3

Documents Produced:   Withheld on grounds of privilege:

5. PRIVILEGE LOG

A privilege log identifying documents withheld on privilege or other protection grounds will be provided. The log will set forth, for each withheld document, a unique identifier, date, author(s), recipient(s), general description sufficient to assess the claim, and the specific privilege or protection asserted.

6. CONTINUING DUTY TO SUPPLEMENT

The responding party has a continuing duty to supplement or amend these Responses if it obtains further information in accordance with applicable rules. Any subsequent production or supplementation shall be without prejudice and shall not be construed as a waiver of any objections or privileges.

7. CONFIDENTIALITY AND PROTECTION

Documents produced that contain confidential, proprietary, or commercially sensitive information are produced subject to any protective order entered in this action. The responding party does not waive any confidentiality protections by production.

8. MISCELLANEOUS

Notices: All written notices regarding these Responses, production, or privilege logs shall be delivered to the counsel identified below at the address provided in the signature block.

Amendments and Waiver: Any amendment to these Responses must be in writing and signed by the responding party or its counsel. No failure to assert any right or objection constitutes a waiver unless such waiver is in writing.

GOVERNING LAW; SEVERABILITY; ENTIRE AGREEMENT

Governing Law: These Responses are governed by the Federal Rules of Civil Procedure and the local rules of the court identified above. To the extent state substantive law applies, such law governs the scope of discoverability.

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

Entire Agreement: These Responses constitute the complete and final written responses of the responding party to the Requests for Production addressed herein and supersede any prior oral or written statements inconsistent with these Responses to the extent they relate to the matters herein.

CERTIFICATION

The undersigned certifies under penalty of perjury under the laws of the United States of America (or the relevant state law where applicable) that the foregoing Responses are true and correct to the best of the signatory's knowledge, information and belief, formed after a reasonable inquiry.

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