Document Responses: Responding to an RFP (CA)

by Practical Law Litigation

A Practice Note explaining how to draft and serve a response to a request for production of documents (RFP), also known as an inspection demand, in a California unlimited civil action. This Note discusses crucial preliminary steps such as calculating the response deadline, implementing a litigation hold to preserve relevant materials, and avoiding spoliation sanctions. It offers guidance on coordinating with the client to collect, review, and produce responsive documents, including electronically stored information (ESI). This Note also covers drafting the formal RFP response, asserting general and specific objections, and preparing a privilege log for withheld or redacted information. It further addresses the mechanics of serving the response and producing documents, including the proper format for ESI and the potential for sanctions.