Kinsey Law Offices 
Response To Request For Production Of Documents
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(Name, Address Of Party or attorney)
____________
____________
____________
State Bar No: ______
(____) _____ - ________
Attorney for _______ (Or "In Pro Per")

 

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ________

 

 

[PLAINTIFF(S) NAMES]
Plaintiffs,

 

v.
 
[DEFENDANT(S) NAMES]
Defendants
 
 
________________________________
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CASE NO: _______
 
RESPONSE TO PLAINTIFF'S FIRST DEMAND FOR PRODUCTION AND INSPECTION

Responding Party: __________ [Plaintiff or Defendant] __________
[name]

Demand for Inspection Set _____ [number of set]

Demanding Party: __________ [Plaintiff or Defendant] __________
[name]

Responding party, __________ [name], the __________
[plaintiff or defendant] in the above cause, makes the following
response to [demanding party's] __________ [first or as the case
may be] Demand for Inspection:

__________ [Respond to each demand separately, using the
number or letters used by the demanding party to identify the
demand, as follows:

1. __________ (Responding party) will comply with this
demand and will permit inspection and __________ (other related
activities demanded) of all __________ (documents or tangible
things or property) in __________ (responding party's)
possession, custody, or control.

2. After engaging in diligent search and reasonable
inquiry, __________ (responding party) is unable to comply with
this demand because __________ (state reason for inability to
comply, such as: the item demanded is no longer in plaintiff's
possession, custody, or control). To the best of __________
(responding party's) knowledge, the __________ (items demanded)
are currently in the possession, custody, or control of
__________ (name), of __________ (address), __________ (city),
__________ County, California.

3. __________ (Responding party) objects to this demand on
the grounds that __________ (basis for objection, for instance:
it demands disclosure of information protected by the work
product rule, in that it calls for inspection of memoranda and
letters written by defendant's attorney to defendant in
preparation for litigation of this action).]

 

Verification

[Choose one of the following as appropriate:]

I, __________ [name], am __________ [plaintiff or
defendant] in the above cause of action. I have read the
__________ [number] inspection demand served on me by __________
[plaintiff or defendant], __________ [name], and my response to
the demand. I am familiar with the contents of both. Based on my
knowledge, the responses to __________ [plaintiff's or
defendant's] inspection demand are true.

I declare under penalty of perjury under the laws of the
State of California that the foregoing is true and correct.

Dated __________.

____________________
[Signature]
Responding Party

[OR, if responding party lacks personal
knowledge of any matter in response]

I declare under penalty of perjury under the laws of the
State of California that the foregoing is true and correct.

Dated __________.

____________________
[Signature]
__________ [capacity of signer]

 

[OR]

I, __________ [name], am authorized to verify this response
on behalf of __________ [organizational party], the __________
[plaintiff or defendant] in the above cause of action. I am
__________ [describe capacity of person verifying response, for
instance: Chief Legal Counsel] for __________ [organizational
party]. I have read the Demand for Inspection, _____ [number]
Set served on __________ [organizational party] and its
Response. I am familiar with the contents of both. I declare
under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.

Dated __________.

____________________
[Signature]
Responding Party
__________ [If required, add the following:

Dated __________.

____________________
(Signature)
Attorney for __________ (responding party)]

 
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