Fill and Sign the Response to Request for Production Mississippi Form

IN THE CIRCUIT COURT OF       COUNTY, MISSISSIPPI       , A MINOR, BY AND THROUGH PARENTS,       and       , PLAINTIFF VS. NO.             , DEFENDANT DEFENDANT'S RESPONSES TO FIRST REQUEST FOR PRODUCTION OF DOCUMENTS COMES NOW, Defendant,       , by and through counsel of record herein, and answers Plaintiff's First Request For Production of Documents as follows, to - wit: REQUEST NO. 1:Each and every document, photograph, recording or physical material of any kind or nature whatsoever which you or your representative contend or believe proves or tends to prove that you were not negligent or that your negligence was not a proximate cause of the accident. RESPONSE: This defendant objects to this Interrogatory in as much as same is vague, overly broad and not calculated to lead to discovery of relevant evidence. Without waiving said objection and without prejudice to this defendant, this defendant would state that discovery is continuing and upon discovery, this Defendant will supplement this Response. This Defendant does have in his/her possession a copy of a statement given by       to the insurance carrier for       . This will be made available at the officer of       ,       ,       , Mississippi, at a time convenient for counsel. REQUEST NO. 2: Any and all written or recorded reports and exhibits or photographs concerning in any manner this litigation and prepared by experts or investigators identified in your request to the Interrogatories propounded to you. RESPONSE: None. REQUEST NO. 3: Produce any and all documents you intend to introduce as evidence in the trial of this cause. RESPONSE: This Defendant has not decided which documents, if any, which will be introduced as evidence in the trial of this case. This Defendant will supplement this Response at a later time pursuant to the Mississippi Rules of Civil Procedure. REQUEST NO 4: All maps, pictures, photographs, plats, surveys, drawings, diagrams, or any other written descriptions which in any manner concern or relate to the accident described in the Complaint filed herein; the scene of the accident. RESPONSE: Discovery is continuing. Upon discovery and development of such documentation, this Defendant will supplement this Response. This Defendant is unaware of any documents at this time. REQUEST NO. 5: All documents upon which you rely in formulating or which are identified or described in your Responses to the Interrogatories, which have been propounded to you. RESPONSE: None. REQUEST NO. 6: All policies of insurance in effect at the time of the accident by or through which you or the owner of the vehicle which you were operating were insured in any manner or to any extent, with respect to damages received by any party as a result of the automobile accident. RESPONSE: This Defendant objects to Request No. 6 in as much as this Defendant was not operating any vehicle at the time of the alleged incident. Respectfully submitted,       , Defendant BY: _____________________________________       , His/Her Attorney CERTIFICATE OF SERVICE I,       , hereby certify that I have this day mailed, by United States mail, postage prepaid, a true and correct copy of the above and foregoing Defendant's Response To Plaintiff's First Request For Production of Documents to:       This the       of       ,       . ________________________________________