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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS
1 at a huge discount visit: http://legaldocspro.net/california-divorce-
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litigation-document-package/
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Be sure to remove these notices and all other notices before using
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6 this document.
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PROPOUNDING PARTY: ANY PETITIONER OR RESPONDENT
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RESPONDING PARTY: ANY PETITIONER OR RESPONDENT
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SET NO.: ONE
17 all exceptions as to competence, relevance, materiality, propriety and admissibility, and any and all
18 other objections and grounds which would require the exclusion of any document herein if the
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request for production, or any documents contained herein were made by, a witness present and
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testifying in court, all of which objections and grounds are reserved and may be interposed at the time
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of trial.
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23 Except for explicit facts admitted herein, no answer or implied admissions are intended
24 hereby. The fact that respondent answered any request for production shall not be taken as an
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admission that respondent accepts certain events or admits the existence of any fact set forth or
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assumed by such request for production, or that such response constitutes admissible evidence. The
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fact that respondent answered part or all of the request for production is not intended and shall not be
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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS
1 construed to be a waiver of all or any part of any objection to any request for production made by
2 respondent.
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The factual background of this litigation is complex. Respondent will, during the course of
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this litigation, pursue extensive formal discovery, as well as extensive investigation and informal
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discovery. The following responses are based upon information presently available to respondent and
7 are made without prejudice to respondents right to utilize subsequently discovered facts and/or
8 documents.
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15 california
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RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS