Legal ROGS Responses

Legal ROGS Responses

Court:    Case No.:

Responding Party Name:    Propounding Party Name:

Recitals

WHEREAS, Responding Party has been served with written discovery consisting of interrogatories, requests for production of documents, and requests for admission propounded by the Propounding Party on ; and

WHEREAS, these Responses to Interrogatories and Requests for Production (collectively "Responses") are provided in good faith subject to the General Objections set forth below and the definitions and instructions contained herein; and

WHEREAS, Responding Party reserves all rights to supplement, amend, or correct these Responses as additional information becomes known or available.

NOW THEREFORE, in consideration of the foregoing and the obligations imposed by the rules of procedure, Responding Party responds as follows.

Definitions and Instructions

1. Definitions. For purposes of these Responses the following definitions apply: "Document" means any written, recorded, or graphic matter, whether produced or stored electronically or in hard copy. "You" and "Your" mean Responding Party and its agents, employees, representatives, and counsel.

2. Scope and Continuing Duty. These Responses are made without prejudice to Responding Party's right to rely upon any objections or privileges as permitted by law and are provided on a continuing basis. Responding Party will supplement these Responses if additional information becomes available.

3. Construction. Each request shall be construed independently and not by reference to any other request. The fact that a portion of a request is answered shall not be deemed an admission as to any other portion of the request.

General Objections

Responding Party objects to each interrogatory or request to the extent that it seeks information protected by the attorney-client privilege, work product doctrine, common interest privilege, or any other applicable privilege or immunity. Responding Party further objects to any request that is vague, ambiguous, overbroad, unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence, or seeks information beyond the applicable temporal, geographic, or subject-matter limits. These general objections shall be deemed to be raised in addition to any specific objections stated for individual requests or interrogatories.

Nothing in these Responses shall be construed as a waiver of any objection to the admissibility of documents or testimony at trial. Responses stating that information is "unknown" or "not reasonably available" are made in reliance upon reasonable inquiry and investigation as of the date hereof.

Specific Responses to Interrogatories

Interrogatory No. 1:

State the full name, current address, and job title of each person known to Responding Party who has knowledge relevant to the claims or defenses in this action.

Interrogatory No. 2:

Describe with specificity the factual basis for each affirmative defense asserted by Responding Party.

Interrogatory No. 3:

Identify all documents that Responding Party intends to rely upon at trial and state the custodian or location of each such document.

Interrogatory No. 4:

State the identity of each insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this action.

Requests for Production — General Response

Responding Party will produce non-privileged, responsive documents in the possession, custody, or control of Responding Party after a reasonable search and subject to the foregoing objections. Privileged documents will be withheld and a privilege log describing the withheld documents will be provided consistent with applicable rules.

Preservation and Supplementation

Responding Party certifies that it has undertaken reasonable efforts to preserve all documents and electronically stored information potentially relevant to the subject matter of this litigation. Responding Party will supplement these Responses in accordance with the rules of procedure should additional responsive information become available.

Certification

I declare under penalty of perjury under the laws of the State of that the foregoing is true and correct to the best of my knowledge, information, and belief as of the date indicated below.

Notices

Amendments; Waiver; Governing Law; Miscellaneous

Amendments. These Responses may be amended or supplemented in writing. No waiver of any objection or privilege shall be implied by disclosure of any non-privileged document or information.

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

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-law rules.

Entire Agreement. These Responses, together with any exhibits and privilege log, constitute the entire understanding between the parties with respect to the subject matter hereof.

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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