Response to Notice For Production (Objections)

UNITED STATES DISTRICT COURT

FOR A SAMPLE DISTRICT

________________________________

) Case [Form] No.:

Peter Plaintiff, )

Plaintiffs, )

)

v. )

Donald Defendant, )

Defendant )

________________________________ )

Requesting Party: _____________

Responding Party: _____________

RESPONSE TO NOTICE FOR PRODUCTION

[Objections]

The Responding Party by and through its attorneys, hereby responds to the Notice For Production of Documents submitted by the Submitting Party on _____________ 20__ as follows:

GENERAL OBJECTIONS

The Responding Party hereby asserts the following general objections (“General Objections”) to each and every one of the Submitting Party’s document requests contained in the Request where applicable. The General Objections may or may not be reasserted after each specific document request. The assertion of the same, similar or additional objections to each specific document request, or the failure to assert any additional objection to each specific document request does not waive or alter the General Objections immediately set forth below:

1. The Responding Party objects to each Request to the extent that it seeks the production of documents and information protected from disclosure by the attorney-client privilege, the work product doctrine and any other privilege, doctrine or immunity.

2. The Responding Party objects to each Request to the extent that it is vague and ambiguous.

3. The Responding Party objects to each Request to the extent that it...