Legal surfer
Junior Member
What is the name of your state? Ohio
Document request. From who? Who do I object to? Statute of limitations defense. Part 2
Letter #3 from Plaintiff:
801133
IN THE CUYAHOGA COUNTY COURT OF COMMON PLEAS
CLEVELAND, OHIO
STATE OF OHIO
DEPARTMENT OF TAXATION
Plaintiff,
vs.
Defendant-husband-and-wife-full-names
Defendant(s)
Case No. JL09123456
PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS TO
THE DEFENDANT(S), Defendant-husband-and-wife-full-names
Plaintiff, STATE OF OHIO DEPARTMENT OF TAXATION, requests, pursuant to Rules 26, 34, and 69 of the Ohio Rules of Civil Procedure, that Defendant(s), Defendant-husband-and-wife-full-names (hereinafter "Defendant(s)"), respond to the following Request for Production of Documents, within twenty-eight (28) days of service herein.
Plaintiff further requests that the documents request herein be mailed or emailed or made available for inspection and copying at the offices of Law-firm-full-name-and-address,
Respectfully submitted,
Signature
Partner-of-law-firm-full-name
Head-of-law-firm-full-name
Partner-of-law-firm-full-name
Partner-of-law-firm-full-address
Partner-of-law-firm-phone-number
Partner-of-law-firm-email
Head-of-law-firm-full-name
Head-of-law-firm-full-address
Head-of-law-firm-phone-number
Head-of-law-firm-email
DEFINITIONS AND INSTRUCTIONS
1. These document requests are continuing and call for prompt and supplementary answers if you obtain additional or different information at a future date.
2. If you object to any of the document requests set forth in writing the specific grounds of the objection
3. If you withhold any documents on the grounds of attorney-client privilege or any other privilege, the work product doctrine, or for any other reason with respect to any communication or document, set forth in writing:
(a) The date and subject matter of the document at issue;
(b) If the privilege is asserted with respect to a document, identify the name, employment and title of each person who prepared, received and has or had possession, custody or control of the document or a copy thereof; and
(c) The basis for the claim of privilege or other ground for failing to identify or produce the document.
If you claim that only part of a document is privileged produce the non-privileged portion(s) of the document.
4. In answering these document requests you are to identify and produce all documents within you possession, custody or control, including, without limitation, documents in the possession, custody or control of your attorney, agents, employees, investigators, consultants and experts, as well as any firm, company, corporation or business in which you own a controlling interest or over which you exercise control in fact. You are required to use reasonable diligence to identify and produce the documents which are not in your immediate possession.
5. The term "document" or "documents" is intended to be as comprehensive, broad, and expansive as the meaning in Rule 34 of the Ohio Rules of Civil Procedure and includes without limitation any written, typed, printed, recorded or graphic matter, however preserved, produced or reproduced, of any type or description, regardless of origin or location, including without limitation any binder, cover note, certificate, letter, correspondence, record, table, chart, analysis, graph, schedule, report, test, study memorandum, note, list, diary, log, calendar, telex, message, electronic or computer or network communication, (including, but not limited to, inter-office an intra-office communications), e-mail, questionnaire, bill, purchase order, shipping order, contract, memorandum of contract, agreement, assignment, license, permit, ledger, ledger entry, book of account, check, order, invoice, receipt, statement, financial data, acknowledgement, transcript, agenda, minutes, work papers, computer or data processing card, computer or data processing disk, computer-generated matter, photograph, photographic negative, phonograph recording, transcript or log of any such recording, projection, videotape, film, microfiche, and all other data compilations from which the information can be obtained, extracted, or translated, reports and/or summaries of investigations, drafts and revisions of drafts of any documents and original preliminary notes or sketches, no matter how produced or maintained, in your actual or constructive possession, custody or control, or the existence of which you have knowledge, and whether prepared, published or released by you or by any other person, and any other physical object containing a written, printed or physical image or sound.. If a document has been prepared in several copies, or additional copies have been made, or copies are not identical (or which by reason of subsequent of a copy by additions of notations or other modifications, are no longer identical), each non-identical copy as a separate document.
6. The term "communication" for purposes of these document requests includes, without limitation, all discussions, conversations, interviews, negotiations, face-to-face meetings, telephone conversations, correspondence, inter-office or intra-office memoranda, email, or other forms of oral or written intercourse, however transmitted, and whether or not transmitted.
7. The term "identify":
(a) when used with reference to a person, shall require a statement of the person's full name, present or last known position, or business affiliation, business address and telephone number, present or last known residential address and telephone number, and if a former employee, the date of employment termination;
(b) when used with reference to documents, shall require a statement, with respect to each non-identical original, draft, copy or photocopy of each document, of the date of the document, the type, the title of the document, the author, and if different, the signatory or signatories, the author's and or other signatories' addresses, the substance thereof, its present or last known location, or custodian, the identification of the person or persons having knowledge of the contents of the document, and all the means of identifying it with sufficient particularity to satisfy the requirements of its identification if a request for its production were made pursuant to Rule 34 of the Federal Rules of Civil Procedure. The documents shall be deemed identical only if they bear, contain or include no writing, signatures, names, notes, marks, words, letters, numbers, signs, stamps, symbols, attachments, or combinations thereof different from those of the other copy or version of the document in question. If such document was, but is no longer, in your possession or subject to your control, state the disposition which was made of it, the reason for such disposition and the date thereof;
(c) when used with reference to a communication, shall require a description of the substance of the communication, the date upon which such communication occurred, the identity of the persons participating in the communication, whether any minutes, notes, memoranda or other record of such communication was made, whether such record now exits and the identity of the person or persons having custody or control of such record.
8. "Relating to" or "Pertaining to" mean consisting of, referring to, referencing, describing, discussing, constituting, evidencing, containing, reflecting, mentioning, concerning, pertaining to, relating to, citing, summarizing, analyzing or bearing any connection with the matter discussed.
9. "Any" shall also mean "all" and vice-versa.
10. The singular shall include the plural, and the plural shall include the singular; and the words "and" and "or" shall both be conjunctive and disjunctive; the masculine article shall include both masculine and feminine.
11. The terms "You" and "Yours" means the persons(s) or entities to whom this discovery request is directed.
12. The term "Plaintiff" means the Plaintiff in this case, including their principals, shareholders, members, directors, offices, employees, and agents.
Continued on part 3.
Document request. From who? Who do I object to? Statute of limitations defense. Part 2
Letter #3 from Plaintiff:
801133
IN THE CUYAHOGA COUNTY COURT OF COMMON PLEAS
CLEVELAND, OHIO
STATE OF OHIO
DEPARTMENT OF TAXATION
Plaintiff,
vs.
Defendant-husband-and-wife-full-names
Defendant(s)
Case No. JL09123456
PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS TO
THE DEFENDANT(S), Defendant-husband-and-wife-full-names
Plaintiff, STATE OF OHIO DEPARTMENT OF TAXATION, requests, pursuant to Rules 26, 34, and 69 of the Ohio Rules of Civil Procedure, that Defendant(s), Defendant-husband-and-wife-full-names (hereinafter "Defendant(s)"), respond to the following Request for Production of Documents, within twenty-eight (28) days of service herein.
Plaintiff further requests that the documents request herein be mailed or emailed or made available for inspection and copying at the offices of Law-firm-full-name-and-address,
Respectfully submitted,
Signature
Partner-of-law-firm-full-name
Head-of-law-firm-full-name
Partner-of-law-firm-full-name
Partner-of-law-firm-full-address
Partner-of-law-firm-phone-number
Partner-of-law-firm-email
Head-of-law-firm-full-name
Head-of-law-firm-full-address
Head-of-law-firm-phone-number
Head-of-law-firm-email
DEFINITIONS AND INSTRUCTIONS
1. These document requests are continuing and call for prompt and supplementary answers if you obtain additional or different information at a future date.
2. If you object to any of the document requests set forth in writing the specific grounds of the objection
3. If you withhold any documents on the grounds of attorney-client privilege or any other privilege, the work product doctrine, or for any other reason with respect to any communication or document, set forth in writing:
(a) The date and subject matter of the document at issue;
(b) If the privilege is asserted with respect to a document, identify the name, employment and title of each person who prepared, received and has or had possession, custody or control of the document or a copy thereof; and
(c) The basis for the claim of privilege or other ground for failing to identify or produce the document.
If you claim that only part of a document is privileged produce the non-privileged portion(s) of the document.
4. In answering these document requests you are to identify and produce all documents within you possession, custody or control, including, without limitation, documents in the possession, custody or control of your attorney, agents, employees, investigators, consultants and experts, as well as any firm, company, corporation or business in which you own a controlling interest or over which you exercise control in fact. You are required to use reasonable diligence to identify and produce the documents which are not in your immediate possession.
5. The term "document" or "documents" is intended to be as comprehensive, broad, and expansive as the meaning in Rule 34 of the Ohio Rules of Civil Procedure and includes without limitation any written, typed, printed, recorded or graphic matter, however preserved, produced or reproduced, of any type or description, regardless of origin or location, including without limitation any binder, cover note, certificate, letter, correspondence, record, table, chart, analysis, graph, schedule, report, test, study memorandum, note, list, diary, log, calendar, telex, message, electronic or computer or network communication, (including, but not limited to, inter-office an intra-office communications), e-mail, questionnaire, bill, purchase order, shipping order, contract, memorandum of contract, agreement, assignment, license, permit, ledger, ledger entry, book of account, check, order, invoice, receipt, statement, financial data, acknowledgement, transcript, agenda, minutes, work papers, computer or data processing card, computer or data processing disk, computer-generated matter, photograph, photographic negative, phonograph recording, transcript or log of any such recording, projection, videotape, film, microfiche, and all other data compilations from which the information can be obtained, extracted, or translated, reports and/or summaries of investigations, drafts and revisions of drafts of any documents and original preliminary notes or sketches, no matter how produced or maintained, in your actual or constructive possession, custody or control, or the existence of which you have knowledge, and whether prepared, published or released by you or by any other person, and any other physical object containing a written, printed or physical image or sound.. If a document has been prepared in several copies, or additional copies have been made, or copies are not identical (or which by reason of subsequent of a copy by additions of notations or other modifications, are no longer identical), each non-identical copy as a separate document.
6. The term "communication" for purposes of these document requests includes, without limitation, all discussions, conversations, interviews, negotiations, face-to-face meetings, telephone conversations, correspondence, inter-office or intra-office memoranda, email, or other forms of oral or written intercourse, however transmitted, and whether or not transmitted.
7. The term "identify":
(a) when used with reference to a person, shall require a statement of the person's full name, present or last known position, or business affiliation, business address and telephone number, present or last known residential address and telephone number, and if a former employee, the date of employment termination;
(b) when used with reference to documents, shall require a statement, with respect to each non-identical original, draft, copy or photocopy of each document, of the date of the document, the type, the title of the document, the author, and if different, the signatory or signatories, the author's and or other signatories' addresses, the substance thereof, its present or last known location, or custodian, the identification of the person or persons having knowledge of the contents of the document, and all the means of identifying it with sufficient particularity to satisfy the requirements of its identification if a request for its production were made pursuant to Rule 34 of the Federal Rules of Civil Procedure. The documents shall be deemed identical only if they bear, contain or include no writing, signatures, names, notes, marks, words, letters, numbers, signs, stamps, symbols, attachments, or combinations thereof different from those of the other copy or version of the document in question. If such document was, but is no longer, in your possession or subject to your control, state the disposition which was made of it, the reason for such disposition and the date thereof;
(c) when used with reference to a communication, shall require a description of the substance of the communication, the date upon which such communication occurred, the identity of the persons participating in the communication, whether any minutes, notes, memoranda or other record of such communication was made, whether such record now exits and the identity of the person or persons having custody or control of such record.
8. "Relating to" or "Pertaining to" mean consisting of, referring to, referencing, describing, discussing, constituting, evidencing, containing, reflecting, mentioning, concerning, pertaining to, relating to, citing, summarizing, analyzing or bearing any connection with the matter discussed.
9. "Any" shall also mean "all" and vice-versa.
10. The singular shall include the plural, and the plural shall include the singular; and the words "and" and "or" shall both be conjunctive and disjunctive; the masculine article shall include both masculine and feminine.
11. The terms "You" and "Yours" means the persons(s) or entities to whom this discovery request is directed.
12. The term "Plaintiff" means the Plaintiff in this case, including their principals, shareholders, members, directors, offices, employees, and agents.
Continued on part 3.
