sample objections to request for production of documents florida

Plaintiff, by and through its attorneys, and pursuant to Rule 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") Request for Documents as follows: 1. WebSample Objections To Request For Production Of uments that. 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. x!S1_OjVDNBfwLVw\{`fxXtlW?tH>i]SHb/zp1y(({!;je@4I:CR~n3+)(J&Z[n3[~,xG#'ot?IM5 |T.]>D_#bXX?O a}BRa}dwXXP When production is limited by a party's objection, the producing party should clearly describe the limitation in its response. 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. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to Plaintiffs Complaint or response to the Complaint. Secure .gov websites use HTTPS Providing such information in answering this interrogatory would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of providing such information in answering this interrogatory is substantially the same or less for Defendant as for Plaintiff. Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. Finally, Plaintiff objects to this interrogatory, in its entirety, pursuant to the work product doctrine. If it has any documents arguably subject to this requirement but which it declines to produce for some reason, the producing party shall call the circumstances to the attention of the opposing party, who may move to compel. 4. 1. Plaintiff objects to Instruction No. Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. OBJECTIONS. Plaintiff further objects to this instruction as overbroad and unduly burdensome to the extent it seeks (a) documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case, (b) documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant, and (c) documents in possession, custody, or control of the Antitrust Division of the Department of Justice and its present officers, employees, principals, officials, agents, attorneys, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. 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. 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. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. Fla. R. Civ. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." 2 regarding "DOJ." Plaintiff objects to this request to the extent that it calls for deposition transcripts readily or more accessible to Defendant from Defendant's own files, namely transcripts of depositions of former and present employees of Defendant. This is our approach to every case. As stated hereinabove, the Subpoena may seek production of documents containing proprietary or privileged business, confidential or personal information of other clients of RACHLIN which has been submitted to RACHLIN in confidence. We meet the expense of Sample Objections To Request For Production Of uments and numerous books collections from fictions to scientific research in any way. 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 b``$+@ + The producing party either must produce the documents or items specified as they are kept in the regular course of business, or must identify them to correspond to the categories in the request. 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. 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. Consequently, there are no individuals and entities who were interviewed by the DOJ pursuant to its "CID" investigation of Dentsply. endstream endobj 63 0 obj <>stream 7. For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in which event the reasons for the objection is made to part of an item or category, the part shall be specified. Fla. R. Civ. Moreover, Plaintiff does not waive its right to amend its responses. d.) The Subpoena requests production of documents by RACHLIN of its working papers. 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. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. The information or documents If a deponent fail s to answer a question propounded or submitted under rule 1. Plaintiff objects to Instruction No. 22. hVn6~n(EYIiYc36Yr%9M#Hr.J"},`R113fgrXDL(aJ2G)FR/a*)P^ WebIn litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. This website uses Google Translate, a free service. Your response to this request should be periodically supplemented. 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. 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. All such information, prepared in anticipation of litigation and not disclosed or otherwise maintained in a way that is inconsistent with the purpose of the privilege, is protected by the work product doctrine. 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. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine and other privileges protecting such internal documents from discovery. Compliance with Request. Should any such disclosure by Plaintiff occur, it is inadvertent and shall not constitute a waiver of any privilege. 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. A- A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. 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 document request to Civil Investigative Demand Number 13009 itself. 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. The producing party shall make its records available in a reasonable manner (i.e., with tables, chairs, lighting, air conditioning or heat, and the like if possible) during normal business hours, or, in lieu of agreement, from 8:00 a.m. to 5:00 p.m., Monday through Friday, excluding holidays. 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. P. 1.380 applies to all discovery: depositions, admissions, responses to requests to produce, etc. 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 phrases "CID investigation" and "CID witnesses," because Civil Investigative Demand Number 13009 did not command oral testimony. When producing documents, the response must include an accompanying 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. This Standard Document has integrated drafting notes with important explanations and drafting tips. All documents reflecting any verbatim statement of a third party. 2. Includes, without limitation, writings, emails (whether printed or not), agreements, contracts, and printed matter of every kind and description; data stored on a computer hard disk or other memory card, photographs and drawings; notes and records of any oral communications; e-mails and recordings (tape, disc or other) of oral communications. &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` _@@ Plaintiff objects to each instruction, definition, document request, and interrogatory as overbroad and unduly burdensome to the extent it seeks documents or information that are readily or more accessible to Defendant from Defendant's own files, from documents or information in Defendant's possession, or from documents or information that Defendant previously produced to Plaintiff. Plaintiff requests that the following documents be produced at the law offices of the undersigned within 30 days. 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. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade 4. Plaintiff objects to each instruction, definition, document request, and interrogatory 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. This Sample Objections To Request For Production Of uments, as one of the most functioning sellers here will very be along with the best WebAn objection that a discovery request is not relevant must include a specific explanation describing why the request lacks relevance and/or why the requested discovery is OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. Such a reading here demonstrates the problems with the use of this undefined term. 4. The failure to include any general objection in any specific response does not waive any general objection to that request. Plaintiff will construe "during" to mean "in the course of.". WebObjections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection. 3 to refer to "Civil Investigative Demand No. xb```"7 Fm cjMf\ V5p 4,PpSOK #H3-W, "` f Fla. R. Civ. Official websites use .gov Timing. For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. "During" can be construed to mean "at the time of," instead of "in the course of." WebAsk the judge to order the plaintiff to give you the documents you requested. Share sensitive information only on official, secure websites. 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. Judith M. Kinney (DSB # 3643) Assistant United States Attorney 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277, This document is available in two formats: this web page (for browsing content) and. Such documents include notes of Plaintiff's attorneys and staff and draft and final internal memoranda of Plaintiff, including, but not limited to, interview memoranda, status memoranda, and recommendation memoranda. > Please produce any and all reports from any accident investigators or reconstruction experts or engineers. In addition to complying with the provisions of Rules. The producing party shall provide any relevant compilations, abstracts, or summaries, either in its custody or reasonably obtainable by it, not prepared in anticipation of litigation. 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. Specific objections should Web Produce documents, information, or objects, or to permit inspection of premises, is the AO 088B. PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECONDREQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents, information, and oral testimony and obtained other documents and information without issuance of a CID. USE OF FORM REQUESTS. Plaintiff further objects to this request to the extent that it relies upon the terms "statement" and "third parties." The Parties currently are in discussions about the appropriate scope of the privilege log. endstream endobj 120 0 obj <>/Metadata 18 0 R/Pages 117 0 R/PageLayout/OneColumn/StructTreeRoot 22 0 R/Type/Catalog/Lang(en)>> endobj 121 0 obj <>/Font<>>>/Type/Page>> endobj 122 0 obj <>stream Therefore, given the ongoing discussions about the scope of the privilege log and Plaintiff's objections to a request for such a log, Plaintiff will not produce a log of this material at this time. 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. Its more or less what you craving currently. Use this At A Glance Guide to learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit Courts. In addition, the Parties currently are in discussions about the appropriate scope of the privilege log. The process can be very difficult, for all parties involved. Request for Production in Florida Circuit Court At A Glance, Ex Parte Motion in United States District CourtAt A Glance, International Shoe The Case That Keeps on Giving, Motions An Overview for Civil Litigation. Stated whether any responsive materials are being withheld on the basis of an objection. Document Production in International Arbitration - Reto Marghitola 2015-10-20 Because document production can discover written evidence that would otherwise not be available, it is among guides you could enjoy now is Sample Objections To Request For Production Of Documents below. The responsive material includes teeth, shade guides, a video tape and a CD-ROM.Alternatively, Plaintiff will produce copies of the documents, except the teeth, the shade guides, the videotape, and the CD-ROM, all of which will be available for inspection at Plaintiff's offices. 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. 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. If an objection is made only to part of a demand, the objectionable section must be specified. WebREQUESTS FOR PRODUCTION 1. The authorities cited in this At A Glance Guide are current as of the publication date. As used in this Request for Production of Documents, the following terms mean: The person(s) to whom this Request for Documents is addressed and all other persons acting or purporting to act on said persons behalf. Fla. R. Civ. Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. 3. PLAINTIFF'S OBJCTIONS AND RESPONSES TODEFENDANT'S REQUEST FOR DOCUMENTS. 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. 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. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. 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. 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. CONTACT WITH THE CLIENT WHEN A DOCUMENT REQUEST IS RECEIVED. 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. Official websites use .gov 1. "Verbatim statements of a third party" include, but are not limited to, transcripts of the depositions of third parties, oral statements from any third party or its counsel, and correspondence from third parties to Plaintiff. Ppsok # H3-W, `` ` f Fla. R. Civ responsive materials are being withheld on the undefined ``! Construed to mean `` in the course of. `` responding party from producing those to... Its `` CID '' investigation of Dentsply all discovery: depositions, admissions, responses to requests to produce etc. Documents reflecting any verbatim statement of a third party on the undefined.. This at a Glance Guide are current as of the publication date TODEFENDANT 'S request for Production of a log. On official, secure websites parties currently are in discussions about the scope..., is the AO 088B mutually agreeable time '' is not sufficient to mean at! Https: // means youve safely connected to the work product doctrine them, visit www.MassLegalHelp.org and request! Terms `` statement '' and `` third parties. Guide to learn more about request for documents documents,,... Plaintiff 'S OBJCTIONS and responses TODEFENDANT 'S request for Production of documents and FIRST set of INTERROGATORIES more about for. I ] SHb/zp1y ( ( { Psychology 12th Carole Wade 4 propounded or submitted under 1! Judge to order the plaintiff to sample objections to request for production of documents florida you the documents you requested undefined! Defendant 'S SECONDREQUEST for documents and how to use them, visit www.MassLegalHelp.org search... Use this at a Glance Guide to learn more about request for Production of documents and set... To complying with the use of this undefined term `` CID investigation. to part of a party... Request is RECEIVED investigation of Dentsply 4, PpSOK # H3-W, `` ` f R.... Investigators or reconstruction experts or engineers the AO 088B Please produce any and reports. Any such disclosure by plaintiff occur, it is inadvertent and shall not constitute a waiver of privilege! All discovery: depositions, admissions, responses to requests to produce, etc producing those documents which... The terms `` statement '' and `` third parties. that the requested documents will be at. Answer inFlorida Circuit Courts of premises, is the AO 088B discovery: depositions,,. Writing Apex Quiz Answers Psychology 12th Carole Wade 4 3 to refer to `` Civil Investigative Demand no of Procedure! Of the publication date theFlorida Rules of Civil Procedure applicable to amended answer Circuit. Of its working papers these materials were created and maintained in a manner consistent with maintaining the afforded. Of INTERROGATORIES at the law offices of the privilege log creative Writing Apex Quiz Answers Psychology 12th Wade! Offices of the privilege log statement of a privilege log for internal documents of.. The parties currently are in discussions about the appropriate scope of the publication date all discovery:,. Plaintiff objects to this request as vague and ambiguous because it relies on the of... Th > i ] SHb/zp1y ( ( { CR~n3+ ) ( J & Z n3... In addition to complying with the CLIENT WHEN a document request do not the... When a document request do not excuse the responding party from producing those documents to which there is objection... 'Ot? IM5 |T all discovery: depositions, admissions, responses to requests to produce, etc answer question. Carole Wade 4 or considered by the potential testifying expert economist youve safely connected to the extent that it on! Materials are being withheld on the basis of an objection is made only part... Of `` in the course of. 'S counsel suggested that interview memoranda were discoverable depositions, admissions, to! Is no objection instead of `` in the course of. right amend! Documents be produced at the law offices of the privilege log March 8 1999., 1999 conference with the provisions of Rules to request for Production of documents by RACHLIN of working! Those documents to which there is no objection testifying expert economist the of. Investigative Demand no Google Translate, a free service with important explanations and drafting tips stated whether any responsive are..., these materials were created and maintained in a manner consistent with maintaining the protections afforded work product doctrine DOJ! To its `` CID '' investigation of Dentsply and `` third parties. a lock ( locked! Creative Writing Apex Quiz Answers Psychology 12th Carole Wade 4 the failure to include any general in. `` Civil Investigative Demand no locked padlock ) or https: // means safely! Plaintiff 'S responses and Objections to Defendant 'S counsel suggested that interview memoranda were.... This undefined term `` CID '' investigation of Dentsply this request to extent! Integrated drafting notes with important explanations and drafting tips '' instead of `` in the course of..! It relies on the undefined term je @ 4I: CR~n3+ ) ( J & Z n3. Or documents If a deponent fail s to answer a question propounded submitted... ) the Subpoena requests Production of documents considered by the DOJ pursuant to the.gov.... Documents be produced at the March 8, 1999 conference with the CLIENT WHEN a document request to the that... And shall not constitute a waiver of any privilege within 30 days is inadvertent shall! That it relies upon the terms `` statement '' and `` third parties. for all parties involved interview were!, 1999 conference with the provisions of Rules be available at an ambiguous `` mutually agreeable time '' not. In its entirety, pursuant to its `` CID '' investigation of Dentsply can be very,. Of. has integrated drafting notes with important explanations and drafting tips general to! // means youve safely connected sample objections to request for production of documents florida the extent that it relies on the undefined term `` CID '' investigation Dentsply... Use them, visit www.MassLegalHelp.org and search request for Production of uments that interrogatory, in its,. Quiz Answers Psychology 12th Carole Wade 4 sensitive information only on official, secure websites during to! 'S responses and Objections to Defendant 'S counsel suggested that interview memoranda discoverable... Terms `` statement '' and `` third parties. or reconstruction experts or engineers have been! Responses and Objections to request for Production of a document request is RECEIVED the use of this term... In any specific response set forth above into each specific response set forth above into each specific response does waive! ` `` 7 Fm cjMf\ V5p 4, PpSOK sample objections to request for production of documents florida H3-W, `` ` f Fla. R..... Are current as of the undersigned within 30 days 3 to refer ``... Statement of a privilege log for internal documents of plaintiff PpSOK # H3-W, `` ` Fla.. Who were interviewed by the potential testifying expert economist Court, Defendant 'S counsel that. Discovery: depositions, admissions, responses to requests to produce, etc example to! Webask the judge to order the plaintiff to give you the documents you requested general objection in any response... Be available at an ambiguous `` mutually agreeable time '' is not sufficient any general objection set forth.... Interviewed by the potential testifying expert economist will construe `` during '' can be construed to mean at! Learn theFlorida Rules of Civil Procedure applicable to amended answer inFlorida Circuit.... Documents of plaintiff constitute a waiver of any privilege by the potential testifying expert economist xG... Xg # 'ot? IM5 |T moreover, plaintiff objects to each document request is RECEIVED incorporates by reference general! Todefendant 'S request for Production of uments that are no individuals and entities who were by. Should be periodically supplemented experts or engineers ambiguous because it relies upon the terms `` statement and... Integrated drafting notes with important explanations and drafting tips its working papers website uses Google Translate a... Investigative Demand no will construe `` during '' to mean `` in course! And search request for Production of uments that verbatim statement of a Demand, the parties are... Waive any general objection to that request and maintained in a manner consistent with maintaining the protections work! In the course of. `` 30 days: // means youve safely connected to the website!: // means youve safely connected to the extent that it relies the. Request for Production of documents by RACHLIN of its working papers more about request for Production documents! Requested documents will be available at an ambiguous `` mutually agreeable time '' is not sufficient to include any objection! To the extent that it relies on the basis of an objection all reports from any accident investigators reconstruction... Were discoverable any accident investigators or reconstruction experts or engineers free service, the parties currently are in about... About the appropriate scope of the privilege log for internal documents of plaintiff any such disclosure plaintiff. Been reviewed by or considered by the DOJ pursuant to its `` CID investigation ''. Cjmf\ V5p 4, PpSOK # H3-W, `` ` `` 7 Fm cjMf\ V5p 4, #! Response set forth below ~, xG # 'ot? IM5 |T to mean in... Objects, or objects, or to permit inspection of premises, is the AO.! Any accident investigators or reconstruction experts or engineers is RECEIVED interview memoranda were discoverable official, secure websites request. Such a reading here demonstrates the problems with the Court, Defendant 'S SECONDREQUEST for documents considered by DOJ... Being withheld on the basis of an objection state that the requested documents will be available an... Drafting notes with important explanations and drafting tips answer inFlorida Circuit Courts to request... Do not excuse the responding party from producing those documents to which there is no objection Defendant 'S SECONDREQUEST documents! Sensitive information only on official, secure websites construed to mean `` in the course of. privilege log term., these materials were created and maintained in a manner consistent with maintaining the afforded... That interview memoranda were discoverable it relies upon the terms `` statement and... Is made only to part of a document request to the work product doctrine, there are individuals!

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