Sample Responses to Request for Production of Documents Under Rule 34

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These sample responses to requests for production of documents under Rule 34 of the Federal Rules of Civil Procedure in United States District Court can be modified for use in many situations. The sample has been revised and updated in December 2016, is 13 pages and includes brief instructions and example responses, a generic verification under oath with notary acknowledgment for use in most states, a specific verification for California only, and proof of service by mail.  The author is a freelance paralegal who has worked in California and Federal litigation since 1995.  Note that the author is NOT an attorney and no guarantee or warranty is provided.