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

Summary

This template objections and responses to a request for production of documents may be used when responding to requests for production of documents (RFPs) served on you or your client in a civil lawsuit in Maryland circuit courts. This template includes practical guidance, drafting notes, and an alternate clause. A party may serve upon any other party a request for production of documents or electronically stored information (ESI) within the scope of Md. Rule 2-402). This form 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 more information on responding to requests for production of documents, see Document Requests: Responding to RFPs (MD). For a related checklist, see Document Requests: Responding to RFPs Checklist (MD) . For an in-depth guide on practicing in Maryland, see Modern Maryland Civil Procedure § 1.1 et seq.