These items help the website operator understand how its website performs, how visitors interact with the site, and whether there may be technical issues. Share sensitive information only on official, secure websites. Plaintiff further objects to Definition No. 8000 IH-10 West, Suite 600 2. Plaintiff objects to Definition No. Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce all non-privileged, responsive documents obtained from third parties during its civil investigation of Dentsply's distribution and marketing of artificial teeth, with the exception that Plaintiff will withhold any documents or material that may contain confidential information until it receives direction from the Court regarding production pursuant to Local Rule 26.2 or a Protective Order has been entered by the Court allowing the production of that material. Number of Interrogatories Because, however, all such transcripts of depositions of third parties taken during its civil investigation of Dentsply's distribution and marketing of artificial teeth may contain confidential information, Plaintiff will withhold production of such transcripts until it receives direction from the Court regarding production pursuant to Local Rule 26.2 or a Protective Order has been entered by the Court allowing the production of that material. 5 regarding "third party" to the extent it relies on the undefined term "CID investigation." Plaintiffs. All such information, prepared in anticipation of litigation and not disclosed or otherwise maintained in a way that is inconsistent with the purpose of the privilege, is protected by the work product doctrine. Subject to the above objections, Plaintiff has no responsive documents in its possession, custody, or control, other than those that have already been produced to Defendant and those being produced as verbatim statements of a third party in response to Request No. 6. DoNotPay has a wealth of legal documents and contract templates to help you out. PDF Selarz Law Corp. Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. A request for production of documents is a discovery device used by opponents in a case to establish the facts before a court can decide the outcome. See Objections 3-4 to Instructions and Definitions ("Objections 3-4").