I am answering a document production request. the question is how literal should I be. they are asking for things that, if i take it exactly as written, do not exist. However if I was more liberal in my interpretation they could exist.
State/Country relating to question: Texas
Hello friend,What are they asking for, exactly, and what do you not have?
they are asking for things that were given to, paid to, created for, held for "persons name, Sr", and nothing has been done with that name and that suffix ever. Now keep in mind that the attorney that filed these is always claiming "type-o's" when he is caught not filling out forms correctly, or in a tight spot with the judge. so i was wondering if we could use that tactic too.
Thank you.If this is so, then individuals in your situation may wish to answer as:"Defendant further objects to this Interrogatory as overbroad and unduly burdensome."or"Defendant currently has no such records."If you really do not have such records, you may let them know as such. Or if this is overly burdensome, you have the right to argue this. And no, it is best to be honest and not to use the same tricks as the other side. "Playing dirty" can have both parties swing mud at each other.I hope this finds you well. Please click Reply to Expert to keep talking, or rate my answer when we are finished. Kindly rate my answer as one of the top three faces only when you are ready (otherwise, hit REPLY to chat more), because this is how I get credit for my time with you. I work very hard to formulate an informative answer for you; please reciprocate my good faith. (You may always ask follow ups free after rating.)
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