Objections and Responses to Requests for Production of Documents
(DC)

Summary

This template is an objections and responses to a request for production of documents that may be used in D.C. Superior Court. This template includes practical guidance, drafting notes, and alternate clauses. Pursuant to D.C. Super. Ct. Civ. R. 34(a), any party may serve upon any other party requests to produce or permit the requesting party to inspect, copy, test, or sample: • Documents • Electronically stored information (ESI) –or– • Tangible things This material is referred to collectively herein as "documents." The responding party then has 30 days to serve responses, except a defendant may serve responses within 45 days after being served with the summons and complaint. D.C. Super. Ct. Civ. R. 34(a)(2)(A). For each item or category, the response must either: • State that inspection and related activities will be permitted as requested –or– • State with specificity the grounds for objecting to the request, including the reasons D.C. Super. Ct. Civ. R. 34(b)(2)(B). You are obligated to produce only documents that are in your possession, custody, or control. D.C. Super. Ct. Civ. R. 34(a)(1). And, you have a duty to supplement your client's responses to requests for production (RFPs), if you learn that the response is incomplete or incorrect. D.C. Super. Ct. Civ. R. 26(e). This template assumes the defendant is responding to a request for production of documents served by the plaintiff. If you represent the plaintiff or co-defendant, you should modify the form accordingly. For a practice note on responding to requests for production of documents, see Document Requests: Responding to RFPs (DC).