Plaintiff's Response to Defendant's First Request for Production of Documents - Personal injury 2025

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The document is a legal response from the Plaintiffs, Estate of ________________, to the Defendant's First Request for Production of Documents in a court case. It outlines general objections regarding the production of documents not in their possession or protected by privilege. The Plaintiffs respond to specific requests for various types of evidence related to an accident, indicating which documents will be produced and which are not available, while also asserting objections to certain requests as overly broad or irrelevant.
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Filing a response is an important first step for any defendant in a civil lawsuit. By filing a response, you establish that you are contesting the case and requiring the plaintiff to prove their case at trial in order to win.
Objections to Evidence: California Misstates the Testimony, Cal. Lack of Foundation/No Personal Knowledge, California Evidence Code 702(a), 800. Incomplete, Cal. Inadmissible Speculation and Conclusions, Cal. Inadmissible Hearsay, Cal. Irrelevant and Prejudicial, Cal. Improper Legal Conclusion.
Common objections to requests for admission include: The request is impermissibly compound. The propounding party may ask you to admit only one fact per statement. You may object to any request that asks you to admit two or more different facts in a single request.
Requests for Production or Demands for Inspection require you to produce documents for copying or in some cases actual items for inspection. Responding to the request has 2 parts: State if you can comply with the request (all of it or some of it) or give the reason why you cant comply.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. The request is vague, ambiguous, or unintelligible. The request is not reasonably calculated to lead to the discovery of relevant, admissible evidence.

sample request for production of documents to plaintiff personal injury

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Any party may serve on any other party a request (1) to produce and permit the party making the request, or someone acting on the requestors behalf, to inspect and copy, any designated documents (including writings, drawings, graphs, charts, photographs, phonorecords, and other data compilations from which information

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