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Anne_C
Anne_C, Attorney
Category: Business Law
Satisfied Customers: 2302
Experience:  Business litigator, 15 years' experience
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I need to respond to a request for documents propounded by

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I need to respond to a request for documents propounded by the plaintiff. I think I need to prepare a pleading paper to accompany the documents. I am unable to find an example anywhere. I am sure there is some boilerplate language including the customary objections and limitations. Can you guide me to a resource where I might find examples like this? I can get to a public law library with Lexus Nexus and WestLaw access, but it is a full day trip. Is there anything online? A repository of example pleadings. Inexpensive or free? California Civil Court. Thanks!

DearCustomer

Hello, it's Anne_C again.

You are going to want to prepare a "Response to Demand for Production of Documents." The applicable code sections are Code of Civil Procedure Section 2031.010 et. seq. Here they are: http://www.leginfo.ca.gov/cgi-bin/displaycode?section=ccp&group=02001-03000&file=2031.010-2031.060 and http://www.leginfo.ca.gov/cgi-bin/displaycode?section=ccp&group=02001-03000&file=2031.210-2031.320

I was not able to find you an example on line. If you can get to a law library, The Rutter Group - Civil Procedure Before Trial has sample response forms that are very helpful.

Briefly, though, you are going to put the responses on pleading paper and call it "[YOUR NAME] RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS". Make sure the document title is in the footer.

After the caption, put: Propounding Party: [Name of the Party]

On the next line, put: Responding Party: [Your Name]

On the next line, put: Set No: [One]

After that, put any general objections that you have to the production of documents.

Then, respond to each request numbering the request and placing any objections to the request you have, then the response in accordance Code of Civil Procedure Section 2031.010 et. seq.

For example, if you have documents and no objections:

RESPONSE TO REQUEST NO. 1

Responding party will produce all documents responsive to this request that are in his care, custody and control.

Make sure to sign the Responses when you are done.

After that, you need to verify the responses, also in accordance with the Code of Civil Procedure. That is a separate page, and you are affirming under penalty of perjury that your responses are true and accurate. That means there are two signatures for you on that document.

After that, you need to serve the documents; don't forget to include a proof of service.

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