Response to Request for the Production of Documents (CA)

by Practical Law Litigation

A Standard Document providing a sample response to a request for production of documents (RFP), also known as an inspection demand, for use in a California unlimited civil action. This Standard Document offers a framework for responding to an RFP pursuant to the California Code of Civil Procedure, addressing key procedural and substantive requirements. It demonstrates how to structure the response, including the caption, preliminary statement, and verification. This Standard Document provides guidance on drafting general and specific objections to document requests, such as those based on attorney-client privilege, the work product doctrine, vagueness, undue burden, or relevance. It also addresses how to articulate a statement of compliance or inability to comply, and how to respond to requests for electronically stored information (ESI). The template covers important considerations for protecting confidential or proprietary information and asserting privilege claims, helping parties prepare a response that properly preserves objections and complies with California's discovery rules.