California Appellate Court Clarifies Request for Production Response Requirements

  1. The production does not have to be verified, only the response;
  2. Bates stamping is not required [but it certainly is smart];
  3. “Already produced all responsive documents” is acceptable.

Pollock v. Superior Court of Los Angeles County

Court of Appeal, Second District, Division 1, California. July 31, 202393 Cal.App.5th 1348311 Cal.Rptr.3d 74423 Cal. Daily Op. Serv. 76602023 Daily Journal D.A.R. 7844

Unlike a response to a production demand, a document production does not have to be verified.

Documents do not need to be Bates labeled through the use of sequential page numbering and a statement of compliance in response to a production demand need not identify the specific request to which the document will pertain.

A party has “already produced all responsive documents” is a code-compliant response so long as a table or other document is provided identifying which documents are responsive to which request number.