Plaintiff further objects to this request to the extent that it relies upon the terms "statement" and "third parties." Fla. R. Civ. Plaintiff objects to Definition No. 4. _ yuj If a deponent fail s to answer a question propounded or submitted under rule 1. HW[O#7~1d. Therefore, there are no "third part[ies]" as that term is defined. Each request is restated below, along with any applicable objections. endstream endobj startxref Compliance with Request. While "CID" is defined in Definition No. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than Notwithstanding said objections, Responding Party answers as follows: -See documents attached as Response No. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of the Antitrust Division. A party who has responded to a request for production with a response that was complete at the time it was provided is under no duty to supplement the response to include after-acquired documents. These responses and objections are made without prejudice to, and are not a waiver of, Plaintiff's right to rely on other facts or documents at trial. Stated whether any responsive materials are being withheld on the basis of an objection. Secure .gov websites use HTTPS Web4. Your response to this request should be periodically supplemented. Plaintiff objects to Instruction No. An official website of the United States government. Copies of certain materials, including internal memoranda to which documents obtained from outside parties may have been attached, are circulated to and may be maintained in files kept in Antitrust Division files other than the principal investigatory and case files. It is not not far off from the costs. Secure .gov websites use HTTPS These interviews were conducted by attorneys and staff of Plaintiff. The information or documents Plaintiff objects to each definition, instruction, and document request as overbroad and unduly burdensome to the extent it seeks documents that are readily or more accessible to Defendant from Defendant's own files or documents that Defendant previously produced to Plaintiff. On the motion you also need to put the date and time for the hearing. Florida Rule of Civil Procedure 1.370 provides that a party may serve upon any other party a written request for the admission of the truth of any matters set forth in Plaintiff objects to Instruction No. All documents reflecting any statement of a third party to the DOJ and signed and/or adopted, formally or informally, by those third parties. ), to whom the referenced Subpoena is directed, by and through his/her undersigned counsel, in accordance with Chapter 120, Florida Statutes, hereby files this Objection and Exceptions to DOH Subpoena No. The failure to include any general objection in any specific response does not waive any general objection to that request. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. In addition to complying with the provisions of Rules. Plaintiff further objects to Definition No. Plaintiff will construe "during" to mean "in the course of.". 76 0 obj <>/Filter/FlateDecode/ID[]/Index[59 31]/Info 58 0 R/Length 87/Prev 100751/Root 60 0 R/Size 90/Type/XRef/W[1 2 1]>>stream WebHere are a handful of those templated objections that could be used during an interrogatory which may be cause for documents to be protected from disclosure. Subject to and notwithstanding this objection, Plaintiff will use the more expansive definition of "third party" that it has provided in above Objection 3, and it will treat "statements" as covering those made by the individuals and entities listed in Plaintiff's Rule 26(a)(1) Initial Disclosures during Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. All of the actual clerical data extraction work shall be performed by the interrogating party unless agreed to the contrary, or unless, after actually beginning the effort, it appears that the task could be performed more efficiently by the producing party. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not Plaintiff objects to this document request as overbroad, burdensome, vague, and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Dentsply's Second Request for Documents and First Set of Interrogatories. It can be a long and tedious process, with much of it occurring outside of the courtroom. Web20. Please produce any and all correspondence or similar communication between any parties to this action. Furthermore, Defendant has access to the addresses and/or telephone numbers of those persons listed on Plaintiff's Rule 26(a)(1) Initial Disclosures and can seek information by addressing formal or informal discovery directly from those entities. As set forth in the correspondence dated March 3, 1999 from Michael S. Spector to Kelly A. Clement, Plaintiff objects to the production of those parties' confidential documents and will not produce those documents unless directed by the Court to do so pursuant to Del. While "CID" is defined in Definition No. Plaintiff further objects to this instruction as overbroad and unduly burdensome to the extent it seeks (a) documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case, (b) documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant, and (c) documents in possession, custody, or control of the Antitrust Division of the Department of Justice and its present officers, employees, principals, officials, agents, attorneys, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. That person shall be one who is fully familiar with the records system and, if a question concerning the records arises and the designated person cannot answer, the producing party should act reasonably and cooperatively in locating someone who knows the answer to the question. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. 3. An attorney's promise that documents will be produced should be honored. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? production of documents shielded from discovery based on work product immunity, attorney-client privilege and other applicable privileges and immunities. 3. endstream endobj Expert witness discovery is governed by 1.280(b)(5), Florida Rules of Civil Procedure. 4. 2 regarding "DOJ." 2. A- in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. Proc., 2033.030(b).) endstream endobj 60 0 obj <> endobj 61 0 obj <>/Rotate 0/Type/Page>> endobj 62 0 obj <>stream OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. Plaintiff will produce responsive, non-privileged documents in the order or arrangement in which they are maintained within the principal investigatory and case files. Defendant's document requests call for the production of documents that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. The Parties currently are in discussions about the appropriate scope of the privilege log. Such a reading here demonstrates the problems with the use of this undefined term. 3 to refer to "Civil Investigative Demand No. If you need to request documents in an employment discrimination case or if you need to respond to a request for documents from the other side, you can get templates from the Legal Help Centers. Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. An official website of the United States government. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. These responses and objections are made without prejudice to, and are not a waiver of, Plaintiff's right to rely on other facts or documents at trial. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine and other privileges protecting such internal documents from discovery. Attorneys and staff of plaintiff which potentially contain confidential sample objections to request for production of documents florida of third parties. midst! 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