[PDF] FTCs Responses to Defendants Objections to Evidence Submitted

What are the responses and objections?

The responses and objections are made on the basis of information and writings currently available to and located by Respondents upon reasonable investigation. Respondents expressly reserve the right to modify, revise, supplement, or amend their responses as they deem

What is a response to a document request?

RESPONSE TO DOCUMENT REQUEST NO. 1: Plaintiff objects to this request to the extent that it calls for documents readily or more accessible to Defendant from Defendant’s own files, including without limitation documents produced by the Defendant to Plaintiff.

What if plaintiff objects to a definition instruction or document request?

5. Plaintiff objects to each definition, instruction, and document request as overbroad and unduly burdensome to the extent it seeks documents that are readily or more accessible to Defendant from Defendant’s own files or documents that Defendant previously produced to Plaintiff.

Does plaintiff consider requests and interrogatory responses relevant or material?

Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests and interrogatory, and responses to the requests and interrogatory, to be relevant or material to the subject matter of this action. 3.