Below are examples of the objections employers can expect to receive on various types of material, and methods to avoid them. Responding party objects to this request to the extent it seeks information protected from disclosure by the attorney-client privilege and/or work product doctrine, or any other applicable privilege. ] . Recently I received an e-mail from an attorney who followed my advice regarding General Objections. The aim is to gain insight into any relevant evidence that the opposing party holds. App. Common mistakes and pitfalls in responses to Requests for Production of (c)(1) If an objection is based on a claim of privilege or a claim that the information 2) my opposing counsel tends to argue that there is no obligation to prepare a privilege log unless it is demanded by the requesting party and I dont think thats right I think its an affirmative duty arising when someone withholds documents under an objection is that right?. Nail Down Whether the Documents You are Seeking ever Existed and Where They are Now, Make Sure You are Aware of the New Document Response Requirements, Start Preparing Your Motion Because with These Responses Youre Going to Court, Why You Need to Bring that Motion To Compel Further Responses to Interrogatories, How a Crafty Lawyer Hides Things by Avoiding the Details when Responding to Requests for Production of Documents, A Needle in a Haystack When Opposing Party Dumps Documents. Court408 F.3d 1142, 2005 WL 1175 922 (9th Cir.2005) [trial court affirmed in holding boilerplate objection without identification of documents is not the proper assertion of a privilege. Unlike Federal Rule Civil Procedure 26(e)(1) (2), California law does not impose a continuing duty on a party to supplement their interrogatory or document responses. Responses to Request for Production of Documents a document request should be straightforward and mechanical so that the responding party 20, 2021), a party requested [d]ocuments sufficient to disclose annual revenue. 1. Defendant objects to Plaintiffs Requests for Production to the extent they seek the
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