Responses to requests for production

[Name]

[Address]

[Phone number]

Attorney for [responding party]

UNITED STATES DISTRICT COURT

FOR THE ___________ DISTRICT OF __________

Civil Action, File Number _________

__________________________________________

)

[Name], ) [RESPONDING

Plaintiff, ) PARTY’S

) RESPONSES AND

v. ) OBJECTIONS TO

) [PROPOUNDING PARTY’S]

[Name], ) REQUEST FOR PRODUCTION

Defendant. )

__________________________________________)

PROPOUNDING PARTY: [Party name]

RESPONDING PARTY: [Party name]

SET NUMBER: [Number]

To [propounding party] and its attorney of record:

Pursuant to FRCP 34(b), [responding party] hereby responds and objects to [propounding party's] [set number] request for production of documents.

GENERAL OBJECTIONS

1. [Responding party] objects to the date on which [propounding party] demands production of responsive documents because it is less than the 30 day period for serving a written response set forth in FRCP 34(b). Notwithstanding this objection, in the interest of ensuring that this case proceeds on an expedited basis, [responding party] will attempt to produce its non-privileged, non objectionable responsive documents on a shortened time schedule. However, [responding party] reserves its right to produce documents after the 30 day time period.

2. [Responding party] shall respond to the requests as if directed only at documents within its possession, custody or control.

3. This response is based upon documents presently available to and located by [responding party] and is given without prejudice to [responding party's] right to produce additional documents at a later date should they become located and available as a result of subsequent review of its records or as a result of additional investigation or discovery.

4. By producing or failing to produce some or all...