To Defendant, __________ [name], and _____ [his or her]
attorney:
[EITHER]
Plaintiff, __________ [name], will comply in full with
defendant's demand for a physical examination as stated in
defendant's demand.
[OR]
Plaintiff, __________ [name], will comply with defendant's
demand for a physical examination with the modification that
__________ [set forth specific modifications, such as: the
physical examination take place at __________ (time), on
__________ (date)].
[OR]
Plaintiff, __________ [name], refuses to comply with
defendant's demand for a physical examination for the following
reasons: __________ [set forth specific reasons for refusal,
such as: The physical demanded by defendant seeks to examine
plaintiff regarding past sexual relationships with persons other
than defendant that occurred more than 15 years ago. Such
matters are beyond the scope of permissible physical examination
under section 2032 of the Code of Civil Procedure].
