Responding to Requests for Production
December 1, 2010
The responding party has 30 days within which to respond to Requests for Production unless a motion for extension of time has been granted or the parties have agreed to different dates.
This requires a writen specific response to each demand or category of items stating the following:
- The items are attached, or that the responding party will comply with specifics of the demand for production and inspection
- The responding party lacks the ability to comply with the demand. Reason should be stated specifically, demonstrating that the responding party has made a due and diligent search for the requested items and why the party is unable to comply.
- While it is not necessary to produce priviledged documents, you must provide a list of all priviledged documents that fall within the scope of the request.
Being organized in production of documents is not only the corteous and professional way to respond, but in the long run it will help you keep track of what has been produced, and to whom.