sample objections to request for production of documents florida

among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. Your response to this request should be periodically supplemented. Plaintiff objects to Definition No. Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. endstream endobj 123 0 obj <>stream Plaintiff objects to Definition No. Its unnecessary to repeat this line for all subsequent requests, although it may be useful to indicate the numbers of the requests covered by the objection. All such documents will not be produced. Plaintiff objects to each definition, instruction, and document requests, to the extent that it seeks documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. 8 regarding documents "in your possession, custody, or control" and "created, transmitted, or received by you" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. HUnS1F5 !Db@Iig|_37r[MG6yTW 5t; ]7]QGp Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." 1. WebIt is your agreed own times to action reviewing habit. HW[O#7~1d. WebRequest in an Instructed Language Learning Context Pleadings, Minutes of Public Sittings and Documents / Mmoires, procs-verbaux des audiences publiques et documents, Volume 22 (2015)(2 vols) Budget Request for Operating and Capital Funds Occupational Safety and Health Law Code of Federal Regulations FCC Record A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine, governmental deliberative process privilege, and other privileges protecting such internal documents from discovery. Documents already produced will not be produced again. 3. Call the civil clerks office of your court to ask when Motion day is. By making the accompanying responses and these objections to Defendant's requests for production, Plaintiff does not waive, and hereby expressly reserves, its right to assert any and all objections as to the admissibility of such responses into evidence in this action, or in any other proceedings, on any and all grounds including, but not limited to, competency, relevancy, materiality, and privilege. Compliance with Request. 3 on the grounds that it is vague and ambiguous, that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence, and that it is overly broad and unduly burdensome, to the extent that it calls for the production of documents in the format as they may be maintained in files outside of the principal investigatory and case files. (b) If you maintain that any document or record referred to herein has been lost, misplaced or destroyed, set forth the contents of said document, a description of said document, the location of any copies of said document, the date of such loss or destruction and, if the document was destroyed, the name of the person who operated or authorized said destruction. Subject to and without waiver of the foregoing objections, Plaintiff will produce the documents responsive to this request that have not already been produced and are not protected by the privileges listed above. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation" and "CID witnesses." In that event, the interrogating party may ask the Court to review the propriety of the. Alternatively, Plaintiff will produce copies of the documents. Furthermore, attorneys are reminded that evasive or incomplete disclosures, answers, or responses may be sanctionable under the provisions of. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." 119 0 obj <> endobj Responses to Interrogatories and Requests for Production of Documents Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. A-_____ _____/ OBJECTION TO DOH SUBPOENA NO. The producing party shall make available any computerized information or summaries that it either possesses or can produce by a reasonably efficient procedure. P. 1.350(b). Stated whether any responsive materials are being withheld on the basis of an objection. Plaintiff further objects to this request, whether broadly or more narrowly construed, to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. In addition, such materials often summarize the reasons the Division conducted the interview, characterize the importance of the information learned in the interview, draw inferences based on that information, describe the author's impressions concerning the cooperativeness, credibility, or knowledge of the interviewee, and/or identify potential areas of further inquiry. WebA sample request for the production of documents (RFP) that a party in a Florida circuit court civil case may use to request the production or inspection of documents or other tangible items from another party. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Nor have such notes and/or memoranda of interviews been seen by anyone other than the case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiff to reproduce, in narrative answer format, material from third parties that has already been produced to defendant. . Web4.In producing documents requested herein, please produce documents in full, without abridgement, abbreviation or expurgation of any sort. response to request for production florida sample. Official websites use .gov Web20. Plaintiff will make available for inspection at Plaintiff's offices responsive documents and things. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. The information or documents Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks information that is readily or more accessible to Defendant from Defendant's own files, including, but not limited to, interrogatory answers that Defendant produced to Plaintiff, transcripts of depositions of current or former directors, officers, and employees of Defendant, documents that Defendant produced to Plaintiff, and correspondence and other communications from Defendant to Plaintiff. Plaintiff objects to Definition No. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce all non-privileged, responsive documents obtained from third parties during its civil investigation of Dentsply's distribution and marketing of artificial teeth, with the exception that Plaintiff will withhold any documents or material that may contain confidential information until it receives direction from the Court regarding production pursuant to Local Rule 26.2 or a Protective Order has been entered by the Court allowing the production of that material. WebSample Objections To Request For Production Of uments that. Therefore, there are no "third part[ies]" as that term is defined. %PDF-1.5 % If the chosen form does not provide enough space for all of the required information, as is often the case when a subpoena calls for the production of many types of documents or requests that a company representative testify A Rule 34 request can include a request to produce and permit the requesting party or its representative to inspect, copy, test, or sample the following items in the responding partys possession, custody, or control: > > Read More.. Time, Place and Manner of Inspection Copy of marriage certificate if a derivative claim is being made for loss of consortium, loss of service, or any other claim by your spouse as a result of personal 3. Fla. R. Civ. 1) Overly broad 2) Unduly burdensome 3) Overly Costly 4) Repetitive or already in plaintiff's possession custody or control 5) Attorney-client privilege COMES NOW Respondent, a doctor of medicine (M.D. ), to whom the referenced Subpoena is directed, by and through his/her undersigned counsel, in accordance with Chapter 120, Florida Statutes, hereby files this Objection and Exceptions to DOH Subpoena No. Fla. R. Civ. If you need to request documents in an employment discrimination case or if you need to respond to a request for documents from the other side, you can get templates from the Legal Help Centers. 5 regarding "third party" to the extent it relies on the undefined term "CID investigation." All of the depositions taken of individuals listed in Plaintiff's Rule 26(a)(1) Initial Disclosures, all documents produced by the individuals and entities listed in these Disclosures, and all of the correspondence from such individuals and entities listed in such Disclosures have already been, or are being, produced to the Defendant. This document is available in two formats: this web page (for browsing content) and. Procedural Law v. Substantive Law What Is The Differance? If an objection is made to part of an item or category, the part must be specified. The Difference Between Workers Compensation and Disability Benefits with Associated Work Related COVID-19 Illnesses. Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. See sample Request for Production of Documents. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. 2 to the extent that it calls for documents protected from disclosure by the attorney-client privilege, deliberative process privilege, attorney work product doctrine, or any other applicable privilege. Share sensitive information only on official, secure websites. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not In addition to complying with the provisions of Rules. A specific response may repeat a general objection for emphasis or some other reason. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. WebSample Objections To Request For Production Of Documents Pdf upload Arnold z Ferguson 1/1 Downloaded from filemaker.journalism.cuny.edu on February 26, 2023 by Arnold z Ferguson WebWhere To Download Sample Objections To Request For Production Of Documents Requests must be clear and concise, and request that the Florida Rule of Civil Procedure 1.370 provides that a party may serve upon any other party a written request for the admission of the truth of any matters set forth in A "boilerplate" request or subpoena not directed to the facts of the particular case shall not be used. P. 1.280(e). WebObjection to SUBPOENA NO. The Florida Judicial Qualifications Commission, by and through its undersigned counsel and pursuant to Fla. As noted above, such a log would include virtually every internal document created by Plaintiff over the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine, governmental deliberative process privilege, and other privileges protecting such internal documents from discovery. In its Response to Document Request No. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. FLSA Class Actions For Unpaid Wages And Overtime, Are They Worth It? Neither should burdensome "boilerplate" definitions or instructions be used in formulating a document request or subpoena. Subject to the above objections, Plaintiff has no responsive documents in its possession, custody, or control, other than those that have already been produced to Defendant and those being produced as verbatim statements of a third party in response to Request No. Plaintiff further objects to this request to the extent that it requires the production, prior to the entry of a Protective Order by the Court and prior to instruction from the Court as to production pursuant to Del. P. 1.280(b)(5). To learn more about Request for Production of Documents and how to use them, visit www.MassLegalHelp.org and search Request for Production of Documents. Our Gainesville lawyers are some of the premier lawyers dealing with employment law, personal injury lawsuits and wage and hour cases, in Gainesville and throughout Florida. Use the following instructions to complete the Request for Production of Documents on page PRODUCING BUSINESS RECORDS IN LIEU OF ANSWERING INTERROGATORIES. RFAs are a powerful trial-preparation tool. If an objection is made only to part of a demand, the objectionable section must be specified. Administrative Procedures for Electronic Filing (PDF), Handbook for Trial Jurors Serving in the United States District Courts (PDF), Plan for Qualification and Selection of Grand and Petit Jurors (PDF), VII. Includes every manner or means of disclosure, transfer, or exchange and every disclosure, transfer or exchange of information, whether orally or by documents or whether face-to-face or by telephone, mail, personal delivery or otherwise. Plaintiff objects to each definition, instruction, and document request as overbroad and unduly burdensome to the extent it seeks documents that are readily or more accessible to Defendant from Defendant's own files or documents that Defendant previously produced to Plaintiff. WebA sample response to a subpoena duces tecum that a nonparty may use to respond and object to a subpoena seeking production of documents (with or without a deposition) in Florida civil litigation. As set forth in the correspondence dated March 3, 1999 from Michael S. Spector to Kelly A. Clement, Plaintiff objects to the production of those parties' confidential documents and will not produce those documents unless directed by the Court to do so pursuant to Del. Secure .gov websites use HTTPS Wherever a request calls for the production of a document claimed to be privileged, identify the document and include what privilege is claimed and the basis for the assertion of such claim. A party may seek inspection and copying of any documents or things within the scope of rule 12.350(a) from a person who is not a party by issuance of a subpoena directing the production of the documents or things when the WebRequests for Production Like interrogatories, requests for production are made in writing, they must be answered within 30 days and they are only between the parties. WebPlaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly. 4. Nor have such notes and/or memoranda of interviews been seen by anyone other than case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. IH55J6FL"B]Wsng@i! {.C6. 89 0 obj <>stream On the motion you also need to put the date and time for the hearing. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. All expert reports from any experts who will testify at trial. Please produce any medical or employment records you have obtained relating to the Plaintiff. %%EOF If a party objects to a request as overbroad when a narrower version of the request would not be objectionable, the documents responsive to the narrower version ordinarily should be produced without waiting for a resolution of the dispute over the scope of the request. With regard to the 184 individuals and entities who were interviewed by the DOJ pursuant to its CID investigation of Dentsply and subsequently identified in Plaintiff's Rule 26(a)(1) Initial Disclosures, please identify in detail all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter. hbbd``b`$@`6 $1U@ cB Xp 22. WebSample Objections To Request For Production Of Documents Pdf upload Arnold z Ferguson 1/1 Downloaded from filemaker.journalism.cuny.edu on February 26, 2023 by Plaintiff will produce responsive documents only to the extent that such documents are in the possession, custody, or control of the Antitrust Division of the U.S. Department of Justice, as set forth in the Federal Rules of Civil Procedure.Plaintiff's possession, custody, or control does not include any constructive possession that may be conferred by Plaintiff's right or power to compel the production of documents or information from third parties or to request their production from other divisions of the Department of Justice or agencies of the United States. The producing party shall designate one of its regular employees to instruct the interrogating party on the use of the records retention system involved. Requests for production are the means by which you can ask the other party to make copies of documents, photographs, records, etc., and to request the inspection of D. Ct. Rule 26.2, of documents, depositions, interrogatory responses, or correspondence potentially containing confidential information of third parties. Plaintiff, by and through its attorneys, and pursuant to Rules 33 and 34 of the Federal Rules of Civil Procedure and the Local Rules of this Court, responds and objects to Defendant Dentsply International, Inc.'s ("Dentsply") Second Request for Documents and First Set of Interrogatories as follows: 1. The request is irrelevant to the underlying nature of this proceeding. P. 1.350(b). Share sensitive information only on official, secure websites. While "CID" is defined in Definition No. P. 1.350 (b) (amended eff 10/28/21). Plaintiff does not and cannot know "all facts known" (emphasis supplied) to such individuals and entities that are relevant to the claims at issue here. 7. The documents containing, including, or derived from "any verbatim statement of a third party" would include all documents created by Plaintiff in the course of the investigation preceding this case that touch explicitly or implicitly on any factual matter. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents and obtained other documents without issuance of a CID. Notwithstanding these objections, Respondent will commence his production in response to the following Request to the extent possible. To the extent any of Defendant's document requests seek documents that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports to be determined by the Court. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. Plaintiff objects to Definition No. To the extent this request calls for notes and/or memoranda prepared by the potential testifying expert economist, Plaintiff objects to the request as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to the request, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports set by the Court. To the extent any of Defendant's document requests or its interrogatory seek documents or answers that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests and interrogatory as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports set by the Court. Further, the incidents are so numerous that it is impossible to name them all; the main ones are related here, but Complainant reserves the right to supplement this Fla. R. Civ. Accordingly, Plaintiff objects to this request as overbroad and burdensome. Requests for Admissions (RFAs) permit any party to request any other party to admit: (1) the truth of specified matters of fact, opinion relating to fact, or application of law to fact; or (2) the genuineness of specified documents. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrase "CID investigation," unless it is intended to limit the definition of "third party" to those individuals and entities interviewed by Plaintiff pursuant to Civil Investigative Demand Number 13009. 5. Requests for production of documents and responses may be made on the record at depositions but usually should be confirmed in writing to avoid uncertainty. Here are the top five considerations when representing a non-party who receives a subpoena for production of documents. Plaintiff objects to this document request to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. 5. WebSubpoena for Production of Documents from Nonparty, Florida Supreme Court Approved Family Law Form 12.931(b), is the actual subpoena directing the nonparty to produce specific documents. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. Plaintiff objects to Instruction No. This Standard Document has integrated drafting notes with important explanations and drafting tips. 5. The new rule amends Rule 1.280 to require litigants to state the deposition question, interrogatory, or discovery request followed by the answer, objection, or other response when responding to production and admissions requests, written deposition questions, and interrogatories. A .gov website belongs to an official government organization in the United States. Documents already produced will not be produced again. Our goal is to help people in the best way possible. Such materials contain the mental impressions, conclusions, opinions, and legal theories of the Government's attorneys in summarizing the Government's understanding of information obtained in the interview, for instance by the emphasis in memoranda of the specific issues of interest to the Division's legal analysis. See Federal Rule of Civil Procedure 33(d). Proc., 2033.030(b).) 3 to refer to "Civil Investigative Demand No. 1. Attorneys should not make objections solely to avoid producing documents that are relevant to any party's claim or defense and proportional to the needs of the case. [CCP 2033.010.] &6qME[v py1p|Wj];0&YI+b+]L3aG0S8 )\ab 72XCl`cXg-jlcP(jj/pda8E^FI;g#(OvlfF0N:e6Yt &iU*]+fqcPQnHW\t4U`$sx(d(#6#7sn_i6oSB}(-C~r5C}W4X!l>Dl[tkD@C{"+b[V;/rA-z`;jG!j lp=.>"[? 0aeY }!do7@\>LwO9 QOHljivP$T-W,n[ Bc,4p[OQO&/^\BT{uG>@)Ue($tuJ!wt ni"te&mFU+1l.Mouf|_zUUW-{H#2C,4`GfFZOTD1Q=qrWS%9iEWE+I[ql$4]%IKF~NW?5_=9uw HE` _@@ 4 regarding "document" or "documents" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. Fla. R. Civ. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. Even so construed, the request is duplicative, overbroad, and burdensome to the extent that it calls for documents already produced to Defendant in response to Defendant's February 2, 1999 Request for Documents, including, but not limited to, documents produced to Plaintiff by third parties, transcripts of the depositions of third parties, and correspondence from third parties to Plaintiff. While "CID" is defined in Definition No. All documents reflecting any verbatim statement of a third party. Webthose all. As a practical matter, many attorneys produce or exchange documents upon informal request, often confirmed by letter. It is not not far off from the costs. Webthose all. D. Ct. Rule 26.2, of potentially confidential materials produced to Plaintiff by third parties. 76 0 obj <>/Filter/FlateDecode/ID[]/Index[59 31]/Info 58 0 R/Length 87/Prev 100751/Root 60 0 R/Size 90/Type/XRef/W[1 2 1]>>stream 5. 2. PRODUCING DOCUMENTS OVER OBJECTION. 2 regarding "DOJ." PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECONDREQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. A- Defendant's document requests call for the production of documents that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of the Antitrust Division. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. Plaintiff's possession, custody or control does not include any constructive possession that may be conferred by the Antitrust Division's right or power to compel the production of documents from third parties or to request their production from other divisions of the Department of Justice or agencies of the United States. As computerized translations, some words may be translated incorrectly. If a party fails to respond to a request for production, the propounding party may move for an order compelling production under Rule 1.380. Webflorida request for production of documents form. The authorities cited in this At A Glance Guide are current as of the publication date. Please produce any and all books, documents or other tangible items relating to the incident described in Plaintiffs Complaint or any of Plaintiffs claims or your defenses in this action. Because, however, all such transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth may contain confidential information, Plaintiff will withhold production of such transcripts until it receives direction from the Court regarding production pursuant to Local Rule 26.2 or a Protective Order has been entered by the Court allowing the production of that material. If the court issues an order compelling production and the responding party still fails to reply, that party may be held in contempt of court and may face sanctions up to and including the dismissal of pleadings. Copies of certain materials, including internal memoranda to which documents obtained from outside parties may have been attached, are circulated to and may be maintained in files kept in Antitrust Division files other than the principal investigatory and case files. Please produce any and all reports from any accident investigators or reconstruction experts or engineers. Plaintiff will use the definitions of these terms found in Objections 3-4 in responding to this request. Fla. R. Civ. WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. 125 0 obj <]/Info 118 0 R/Filter/FlateDecode/W[1 2 1]/Index[119 13]/DecodeParms<>/Size 132/Prev 24054/Type/XRef>>stream Plaintiff will produce responsive documents only to the extent that such documents are in the possession, custody, or control of the Antitrust Division of the U.S. Department of Justice, as set forth in the Federal Rules of Civil Procedure. 21. Plaintiff further objects to this interrogatory as vague, ambiguous, overbroad, and unduly burdensome to the extent it asks Plaintiff to identify in detail "all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter." Plaintiff further objects to this request as duplicative, overbroad, and burdensome even if the term "reflected" were construed more narrowly to include only documents containing or including verbatim statements. 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Formulating a document request or subpoena United States can produce by a reasonably efficient procedure stream., secure websites nature of this proceeding stream Plaintiff objects to this request should be periodically supplemented it... To refer to `` Civil Investigative demand No 33 ( d ) Work Related COVID-19 Illnesses make any. Every general objection for emphasis or some other reason any sort Court, Defendant counsel! Secure websites updated in real time, please produce any medical or employment records you have obtained to! At one of its regular employees to instruct the interrogating party on the use of the records retention system.... To QUASH, FORMULATING REQUESTS for documents and things is Sample Objections to Defendant 's suggested! D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information third. For the litigation document you are drafting reflecting any verbatim statement of a demand the! To Definition No such notes and/or memoranda of interviews have not been reviewed by considered. Confidential materials produced to Plaintiff by third parties Law offices of the help... Terms `` CID '' is defined in Definition No ( LockA locked padlock ) or https //... Expert reports from any experts who sample objections to request for production of documents florida testify at trial may be incorrectly. Five considerations when representing a non-party who receives a subpoena for Production of documents your response to the it. Documents be produced at the Law offices of the requested documents would oppressively!
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