1 Any Attorney or Party

Any Street
2 Any Town, CA 55555
3
714-555-5555
4

5 Any Attorney or Party

6

8 Superior Court of the State of California

For the County of ________________
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10

11 Any Plaintiff, ) Case No.

)
12 ) Responses to Requests for Production of
Plaintiff, ) Documents, Set One
13 )
vs. )
14 )
Any Defendant, and DOES 1-5 )
15 )
)
16
Defendants. )
)
17

18
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- 1 -
RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 http://legaldocspro.net/california-discovery-litigation-document-
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Be sure to remove these notices and all other notices before using
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6 this document.
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PROPOUNDING PARTY: NAME AND CAPACITY OF PROPOUNDING PARTY
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RESPONDING PARTY: NAME AND CAPACITY OF RESPONDING PARTY
9

10
SET NUMBER: ONE

11 TO: NAME AND CAPACITY OF PROPOUNDING PARTY AND THEIR ATTORNEYS

12 OF RECORD:
13
NAME AND CAPACITY OF RESPONDING PARTY hereby responds and objects to the
14
Requests for Production of Documents, set one as follows:
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General Statement
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17 These responses are made solely for the purposes of this action. Each answer is subject to

18 all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all
19
other objections and grounds which would require the exclusion of any document herein if the
20
request for production, or any documents contained herein were made by, a witness present and
21
testifying in court, all of which objections and grounds are reserved and may be interposed at the
22

23 time of trial.

24 Except for explicit facts admitted herein, no answer or implied admissions are intended
25
hereby. The fact that respondent answered any request for production shall not be taken as an
26
admission that respondent accepts certain events or admits the existence of any fact set forth or
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28

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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE
 1 assumed by such request for production, or that such response constitutes admissible evidence. The
2 fact that respondent answered part or all of the request for production is not intended and shall not
3
be construed to be a waiver of all or any part of any objection to any request for production made
4
by respondent.
5

6
The factual background of this litigation is complex. Respondent will, during the course of

7 this litigation, pursue extensive formal discovery, as well as extensive investigation and informal

8 discovery. The following responses are based upon information presently available to respondent
9
and are made without prejudice to respondents right to utilize subsequently discovered facts and/or
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documents.
11
To the extent that the requests for production purport to require disclosure of confidential
12

13 attorney-client communications and/or protected work product, respondent objects. No waiver of

14 privilege is intended or should be implied from any of the responses to the request for production.
15
Discovery is continuing and the responding party reserves the right to amend these response
16
at a later date to incorporate later discovered facts and/or documents.
17
This general statement is incorporated into each of the responses set forth below.
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19 RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS

20 RESPONSE TO REQUEST FOR PRODUCTION NO. 1:

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Responding party will comply and will produce all documents in their possession, custody
22
and control. Discovery is continuing and the responding party reserves the right to amend this
23
response at a later date to incorporate later discovered facts and/or documents.
24

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28 requests-for-production-of-documents-for-california
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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE