Requests for Production Response Template
Five documents and three sheets that answer each request, say what the objection withholds, and map every Bates range back to the request it satisfied.
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Request Register
[Matter] · responses to [party]'s first requests for production
One row per request. The objection and what it withholds are separate cells, because the rule asks two things and a form bank answers one.
| # | Objection ground | Withheld on that basis? | Response | Bates |
|---|---|---|---|---|
| [n] | None asserted | n/a | Producing | [range] |
| [n] | [the ground, stated with specificity] | Yes. [what is being withheld] | Producing the rest | [range] |
| [n] | [the ground] | No | Producing in full | [range] |
| [n] | None asserted | n/a | No responsive documents exist | none |
The two rows that look identical and are not
Row three objects and withholds nothing. Row four has nothing to withhold. One is a preserved ground, the other is a factual representation about the client's records, and collapsing them into produced subject to objections loses both.
Every bracket fills from your own served requests. Nothing here ships with an objection already in it.
An objection is two statements and every form bank ships one. Rule 34(b)(2)(C) requires an objection to state whether any responsive materials are being withheld on the basis of it, and an objection to part of a request to specify the part and permit inspection of the rest. So each row carries the ground and the withholding statement in separate cells, because a response that answers the first and skips the second is deficient on the face of the rule however well the objection reads.
The production is part of the response too. The same rule gives two options and only two: produce documents as they are kept in the usual course of business, or organize and label them to correspond to the categories in the request. Electing to produce copies instead of permitting inspection also puts a completion date inside the response, so rolling basis with no date stated is an omission rather than an election. The register records which option you took, against which Bates ranges.
Then somebody has to swear to it. Interrogatory answers are made under oath by the party, and for a corporation by an officer or agent who must furnish the information available to it, while the attorney signs the objections. Two signatures from two people, and one of them is routinely unidentified until the week it is due. Entries withheld for privilege go to the log written to the elements of each claim, and what actually goes out gets checked by the load file and image validation.
What's in the pack
Request Register
One row per request, with the ground and the withholding statement in separate cells, the responsive set, the Bates range and whether the item is complete.
Responses and Objections
The response document in pleading format, each item carrying its ground stated with specificity, what is withheld on that basis, and the production it points at.
Production Map
Request to Bates range to document count, with the usual-course or labelled-to-the-categories election stated once and the evidence for it on the row.
Verification
The client's signature block for the answers, separate from the attorney's for the objections, with the declaration wording and the named officer who furnishes the information.
Deadline Tracker
Every date computed from the service date: responses, each stated completion date, the verification, the log, and the supplementation trigger.
Meet and Confer Letter
Built from the register's open rows, so the letter argues about specific requests with the withholding statements quoted rather than about tone.
What Was Not Produced
Requests with no responsive documents, sets outside a party's possession, custody or control, and every item still open, each distinguished from the others.
Two Signatures and a Production
The method doc: what a complete response consists of, and why the privilege log is a separate artifact with its own standard.
How to use it
- 1
Open in River, or take it blank
Open the pack in River and hand it the served requests, or download the Word documents and CSV sheets from the template library and fill them in yourself.
- 2
Send what was served
The requests and interrogatories as served, the certificate of service, any ESI protocol or discovery plan already agreed, and the scheduling order if one exists.
- 3
Each request gets two answers
The ground, stated with specificity against that request, and whether anything is being withheld because of it. Neither is inherited from a general objections block.
- 4
A person signs, then it goes
The attorney signs the objections and a named officer signs the answers. The register shows every request still missing one of the two.
Frequently asked questions
Is this template free?
Yes. The zip is Word documents and CSV sheets, no account and no card. Edit with AI is the other half: the agent reads the served requests, builds the register, and drafts each objection with the ground and the withholding statement as separate fields. Other packs sit in the template library.
What format are the downloaded files?
Word (.docx) for the five documents and CSV (.csv) for the three sheets, zipped together. Excel, Numbers and Google Sheets open the registers straight off the download, and the response, verification and letter open in Word or Pages. Nothing to convert.
Does it write the objections for me?
It drafts them against the request in front of it, with the ground stated to that request rather than pulled from a block. Every draft is for the signing attorney to check and own, because the signature certifies a reasonable inquiry and the sanction for a certification that violates the rule without substantial justification is mandatory rather than discretionary.
Does the verification need a notary?
Not in federal court. Section 1746 of Title 28 lets an unsworn declaration subscribed as true under penalty of perjury and dated stand in for a sworn one. The prescribed form differs depending on whether it is executed inside or outside the United States. It expressly does not reach depositions.
What about the documents we are withholding for privilege?
They leave this pack. The register records the count and the request each withheld set answers, then the log written to the elements of each privilege claimed takes over, because a log entry has to establish a claim rather than describe a document. The two artifacts are served together and built separately.
How is this different from checking the production itself?
This is the written response and what it points at. Whether the files you send survive the other side's ingest is a separate problem. Validating the load file, the images and the natives against each other catches the defects that cause a rejected load. No amount of care in the response document prevents one of those.
What does 'Edit with AI' actually do?
It signs you up, installs this exact pack as a private workspace, and puts the agent in front of an empty Request Register. Then you send the requests as served, and the first thing back is the deadline set computed from the certificate of service rather than from memory.
Answer every request twice, and map what went out
Take the Word documents and CSV sheets blank, or open this exact pack in River and hand it the requests as served.
Edit with AI