Objections and Responses to Requests for Production of Documents
(Defendant to Plaintiff) (Federal)

Summary

This template is a set of objections and responses to requests for production of documents (RFPs) that a defendant may use in a federal district court case. It includes practical guidance, drafting notes, and alternate and optional clauses. Document requests, or RFPs, are written requests served between parties in civil litigation seeking production of relevant documents and electronically stored information (ESI). Fed. R. Civ. P. 34. Rule 34(a) permits a party "to inspect, copy, test, or sample" "any designated documents or electronically stored information" and any "designated tangible thing" in the responding party's possession, custody, or control." Fed. R. Civ. P. 34(a)(1). These requests provide broad access to other parties' information but can quickly become expensive and yield an overwhelming amount of material. A party responding to a document request has an obligation to conduct a diligent search to locate documents responsive to the requesting party's document request. Rogers v. Giurbino, 288 F.R.D. 469, 485 (S.D. Cal. 2012) (internal quotation marks and citations omitted); see A. Farber & Partners, Inc. v. Garber, 234 F.R.D. 186, 189 (C.D. Cal. 2006). Each individual response must state that you will make the requested material available for inspection or (more commonly) will produce copies in lieu of inspection. Fed. R. Civ. P. 34(b)(2)(B). Related Content For a full listing of key content covering fundamental civil litigation tasks throughout a federal court litigation lifecycle, see Civil Litigation Fundamentals Resource Kit (Federal). For more on responding to document requests, see Document Requests: Responding to RFPs (Federal). For related templates, see: • Objections and Responses to Requests for Production of Documents (Plaintiff to Defendant) (Federal) • Requests for Production of Documents (RFPs) (Plaintiff to Defendant) (Federal) • Requests for Production of Documents (RFPs) (Defendant to Plaintiff) (Federal) For a list of additional related resources, see Document Review and Production Resource Kit (Federal)