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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.
What Is a Request for Production of Documents? 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.
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.
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.
California law places strict limits on the number of discovery requests a party can make. In a limited civil case (cases less than $25,000) you may ask each party only 35 questions total, whether they are form interrogatories, special interrogatories, requests for admission, or requests for production.
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WITHOUT WAIVING THESE DEFENSES, I RESPOND AS FOLLOWS: I am producing all of the requested documents that exist. I am producing all of the requested documents in my possession. I have requested copies of additional documents and expect to produce them by ___________________________ (date).
Interrogatories are a discovery tool that the parties can use to have specific questions about a case answered before trial. Interrogatories are lists of questions sent to the other party that s/he must respond to in writing.
In an unlimited civil case (cases over $25,000), each party may make 35 requests for admission. Any number over 35 may be asked if the request contains a declaration of necessity, a sworn statement in which the party or attorney declares under penalty of perjury that additional discovery is required.
If you have received requests to produce, you have thirty days to prepare your written responses (unless the court has ordered something else). You do not file your written responses with the court. You simply mail the original back to the other side.
Requests for production of documents have an important advantage over other discovery methods due to the fact that there is no numerical limit to the number of requests specified in California law. However a party served with excessive requests may seek leave of court to limit the number of requests.

california request for production of documents