Legal ROG Responses

Legal ROG Responses

This Responses to Interrogatories is made by Responding Party: and Propounding Party: in the action captioned Case No.: in . Date of service of the Interrogatories: .

Recitals

WHEREAS, Propounding Party served Interrogatories, Set No. upon Responding Party seeking information relevant to the claims and defenses in this action;

WHEREAS, Responding Party responds to each interrogatory below subject to the General Objections set forth in Section 2, and subject to any privilege or protection from disclosure described in the Privilege Log section of this document;

WHEREAS, these Responses are made without waiver of any rights, objections, or defenses, and are provided with the continuing duty to supplement as required by law.

NOW THEREFORE, Responding Party hereby states the following Responses to the propounded Interrogatories.

1. Definitions

For purposes of these Responses, the following definitions apply: "Interrogatories" means the written questions propounded by Propounding Party, and "Document" shall have the broadest meaning consistent with applicable discovery rules. To "Identify" a natural person means to provide full legal name, last known address, and last known employer. To "Identify" a document means to state its type, author, date, and current location or custodian.

2. General Objections

Responding Party objects to each Interrogatory to the extent it seeks information protected by the attorney-client privilege, the attorney work product doctrine, or any other applicable privilege or immunity. Without waiving these objections, Responding Party responds to the extent information is non-privileged and reasonably available. Responding Party further objects to any Interrogatory that is overly broad, unduly burdensome, vague, ambiguous, or seeks information not relevant to the subject matter of this action or proportional to the needs of the case. These General Objections are incorporated into each specific response.

3. Specific Responses to Interrogatories

Interrogatory Response 1

Interrogatory No.: — Text of Interrogatory:

Objections (check all that apply):

Overbroad Vague/Ambiguous Privileged Undue Burden Irrelevant

Response:

Documents produced in response to this Interrogatory:

Interrogatory Response 2

Interrogatory No.: — Text of Interrogatory:

Objections (check all that apply):

Overbroad Vague/Ambiguous Privileged Undue Burden Irrelevant

Response:

Documents produced in response to this Interrogatory:

Interrogatory Response 3

Interrogatory No.: — Text of Interrogatory:

Objections (check all that apply):

Overbroad Vague/Ambiguous Privileged Undue Burden Irrelevant

Response:

Documents produced in response to this Interrogatory:

4. Privilege Log

Where Responding Party withholds documents or information on the basis of privilege or protection, Responding Party will provide a Privilege Log that identifies, for each withheld document, the date, author, recipients, general description of the document sufficient to evaluate the claim of privilege, and the specific privilege or protection asserted.

Privilege Log Entry (example)

5. Continuing Duty to Supplement

Responding Party acknowledges a continuing obligation to supplement these Responses if Responding Party learns that the Responses are materially incomplete or incorrect and will serve further amendments or supplements in accordance with the applicable rules and court orders.

6. Production and Format

Documents responsive to the Interrogatories will be produced in a reasonably usable electronic format or as otherwise agreed by the parties. To the extent production is delayed due to volume, privilege review, or third-party holdings, Responding Party will promptly advise Propounding Party and will provide rolling productions.

7. Verification and Certification

I, , declare under penalty of perjury under the laws of the state identified below 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.

8. Notices

All notices required or permitted under these Responses shall be in writing and served on counsel of record or on the parties at the addresses provided below.

9. Amendments; Waiver; Counterparts

These Responses may be amended or supplemented by written instrument signed by the person making the amendment. No waiver of any provision in these Responses will be effective unless made in writing and signed by the party waiving the provision. These Responses may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one instrument.

10. Governing Law; Entire Agreement; Severability

Governing Law: These Responses shall be governed by and construed in accordance with the laws of the state of , without regard to its conflict of laws principles.

Entire Agreement: These Responses, including any attachments and Privilege Log, constitute the entire record of Responding Party's written answers to the Interrogatories specified above and supersede any prior oral or written statements to the extent they conflict with these Responses.

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

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