1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 UNITED STATES DISTRICT COURT

9 ___________ DISTRICT OF __________

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11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) RESPONSES TO REQUESTS FOR ADMISSION,
) SET ONE
13 vs. )
)
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
17

18
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- 1 -
RESPONSES TO REQUESTS FOR ADMISSION, SET ONE
 1 PROPOUNDING PARTY: Any Party
2
RESPONDING PARTY: Any Party
3
SET NUMBER: One
4
TO _______________AND THEIR COUNSEL OF RECORD:
5

6 Pursuant to the provisions of Federal Rule of Civil Procedure 26 and 36, ___________herein

7 responds and objects as follows to the Requests for Production of Admission, Set One propounded by
8
___________.
9

10
Dated________________ _______________________________________________
11 ANY ATTORNEY OR PARTY
12

13 GENERAL STATMENT

14 It should be noted that this responding party has not fully completed investigation of the facts
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relating to this case, and has not fully completed discovery in this action and has not completed
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preparation for trial. All of the answers contained herein are based upon such information and
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documents which are presently available to or specifically known to this responding party and
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19 disclose only those contentions which presently occur to such responding party.

20 It is anticipated that further discovery, independent investigation, legal research and analysis
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will supply additional facts, add meaning to known facts, as well as establishing entirely new factual
22
conclusions and legal contentions, all of which may lead to substantial additions to, changes in, and
23
variations from the contentions herein set forth. The answers contained herein are made in a good
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25 faith effort to supply as much factual information and as much specification of legal contentions as is

26 presently known which should in no way be to the prejudice of defendant in relation to further
27
discovery, research and/or analysis.
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RESPONSES TO REQUESTS FOR ADMISSION, SET ONE
 1
The responding party has based these responses on the assumption that in propounding these
2

3 requests for admission, the propounding party does not seek materials protected against discovery by

4 (a) attorney/client privilege; (b) the attorney work product doctrine; (c) litigation privilege; (d)
5 constitutional or statutory right of privacy; (e) the confidentiality of statements or conduct made for
6
settlement purposes; (f) trade secrets or other proprietary information or privileges; or (g) materials
7
which are irrelevant to the subject matter of this litigation.
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RESPONSES TO REQUESTS FOR ADMISSION, SET ONE