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An overly broad discovery request lacks specificity as to time, place, and/or subject matter being requested. However, overbroad is not a valid objection unless it can be shown that the request imposes an undue burden or seeks discovery that is not relevant to the subject matter of the case.
A request for production is a legal request for documents, electronically stored information, or other tangible items made in the course of litigation.
A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.
In general, the purpose of the document production procedure is to enable a party to establish the facts on which the party relies or to contest the facts underpinning the other partys case. Document production as a means of proving the facts of a dispute is available in most national legal systems.
These objections typically assert a general ground for objection that would be preserved whether stated or not. Some examples of these objections include: Objections to the extent that a request or interrogatory implicates privileged material.
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Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
* Overbroad and BurdensomeThe showing required to sustain this objection is that the intent of the party was to create an unreasonable burden, or that burden created does not weigh equally with what requesting party is trying to obtain from it. See Mead Reinsurance Co. v. Superior Court (1986) CA3d 313.
Objections that may be used in the course of discovery include, but are not limited to the following: Unduly burdensome, Overly broad. Vague. Ambiguous. Disproportional. Protected by the attorney-client privilege. Work product doctrine.
Your response to a request for production consists of two parts: One part is a written response to the requests, in which you state under penalty of perjury that you will produce the requested items; that you will not produce and why; or that you object to a request on legal grounds.
The process of delivering, or making available for review, documents in response to a request for documents, such as a request for production and a subpoena. A request for documents may call for the production of paper (hard copy) documents and electronically stored information (ESI).

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