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[NAME OF FIRM]
[Lead Counsel’s Name] (SBN [Number])
Email:
[Other Counsel’s Name] (SBN [Number])
Email:
[Address]
Los Angeles, California [Zip]
Telephone:
Facsimile:
Attorneys for Plaintiff
[Name of Plaintiff]
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
Plaintiff,
v.
[NAME OF DEFENDANT],
Defendant. / Case No. [Number]
PLAINTIFF’S OBJECTIONS & RESPONSES TO DEFENDANT’S FIRST SET OF REQUESTS FOR ADMISSION TO PLAINTIFF
Judge:
Trial Date:
PROPOUNDING PARTY: [Defendant]
RESPONDING PARTY: [Plaintiff]
SET NO:One
Plaintiff [Name] hereby responds to Defendant [Name]’s First Set of Requests for Admission (the “RFAs”) as follows:
PRELIMINARY STATEMENT
These responses are made solely for the purpose of this action. Each response is subject to all applicable objections as to competence, relevance, materiality and admissibility, as well as to any and all other objections on any grounds that would require the exclusion of any statement therein in Court. [Plaintiff] has not yet completed its investigation of the facts relating to this action; has not yet reviewed all documents relating to this action; has not yet interviewed all witnesses in this action; has not yet completed its discovery in this action; and has not yet completed its preparation for trial. All responses are given on the basis of present recollection and are given without prejudice to [Plaintiff]’s right to amend or supplement its responses herein.
Except for facts explicitly admitted herein, no admissions of any nature whatsoever are implied or should be inferred. The fact that any individual request (“Request”) herein has been objected to should not be taken as an admission or acceptance of the existence of any facts set forth or assumed by such Request, or that such constitutes admissible evidence.
GENERAL OBJECTIONS
To the extent applicable, the following General Objections are incorporated inthe response to each and every individual Request:
1. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they purport to impose on [Plaintiff] obligations not imposed by the Federal Rules of Civil Procedure, the LocalRules of the Central District of California, or other applicable rules or authority.
2. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they seek information thatis not within [Plaintiff]’s possession, custody, or control. These responses are madeon behalf of [Plaintiff] only. [Plaintiff] objects to this discovery to the extent it seeksinformation from any other entity or person.
3. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they seekinformation in thepossession of [Defendant] or readily available to [Defendant], or equally accessible to bothparties.
4. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they seek informationprotected by the attorney-client privilege, the attorney work product doctrine, or any other applicable privilege or immunity. To the extent that a Request calls for information protected by the attorney-client privilege, the attorneywork product doctrine, or other applicable privilege orprotection, [Plaintiff] hereby claims such privilege and invokes such protection. Thefact that [Plaintiff] does not specifically object to an individual Request on the groundthat it seeks privileged or protected information shall not be deemed a waiver ofthe protection afforded by the attorney-client privilege, the attorney work productdoctrine, or other applicable privilege or protection. Any inadvertent production of privileged or protected material shall not be deemed a waiver of any such privilege or protection.
5. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they are compound, repetitive,overbroad, unduly burdensome and/or oppressive.
6. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they seekinformation whichis not relevant to any party’s claims or defenses, nor reasonably calculated to lead to the discovery of admissible evidence.
7. [Plaintiff] objects to the RFAs and to each Requesttherein to the extent they are not proportional to theneeds of the case and/or seek to impose discovery obligations on [Plaintiff] where thebenefit of conducting the discovery is outweighed by the cost and burden of doing so.
8. [Plaintiff] reserves the right to challenge the competency, relevancy,materiality and admissibility of and to object on any ground to the use of information set forth in or produced in accordance with these responses at any subsequent proceeding or the trial of this or any other action.
SPECIFIC OBJECTIONS
REQUEST FOR ADMISSION NO. 1
Admit that [Defendant] never prevented you from performing under the Training Agreement.
RESPONSE TO REQUEST FOR ADMISSIONNO. 1
[Plaintiff] incorporates herein by reference its General Objections. [Plaintiff] further objects to the Request on the grounds that it seeks to impose upon [Plaintiff] the burden and expense of investigating, identifying, or verifying information [Defendant] has the equal ability to investigate, identify, or verify on his own.
REQUEST FOR ADMISSIONNO. 2
Admit that [Defendant] never indicated to you that he no longer desired your services under the Training Agreement.
RESPONSE TO REQUEST FOR ADMISSIONNO. 2
[Plaintiff] incorporates herein by reference its General Objections. [Plaintiff] further objects to the Request on the grounds that it seeks to impose upon [Plaintiff] the burden and expense of investigating, identifying, or verifying information [Defendant] has the equal ability to investigate, identify, or verify on his own.
REQUEST FOR ADMISSIONNO. 3
Admit that you currently have separate training agreements in place with other clients for other races.
RESPONSE TO REQUEST FOR ADMISSIONNO. 3
[Plaintiff] incorporates herein by reference its General Objections. [Plaintiff] further objects to the request on the grounds that it is vague, overbroad and unduly burdensome.
REQUEST FOR ADMISSIONNO. 4
Admit that you still retain the same client base as you did one year ago.
RESPONSE TO REQUEST FOR ADMISSIONNO. 4
[Plaintiff] incorporates herein by reference its General Objections. [Plaintiff] further objects to the request on the grounds that it is vague, overbroad and unduly burdensome.
Dated:[Date] / [LAW FIRM]By:
[Lead Counsel’s Name]
[Other Counsel’s Name]
Attorneys for Defendant
[Name]
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[PLAINTIFF]’S OBJECTIONS AND RESPONSES TO [DEFENDANT]’S FIRST SET OF REQUESTS FOR ADMISSION