sample objections to request for production of documents florida

Please keep this in mind if you use this service for this website. The applicable general objections, as stated above (General Objections), are incorporated into each of the specific objections and responses that follow. It is not not far off from the costs. Creative Writing Apex Quiz Answers Psychology 12th Carole Wade All expert reports from any experts who will testify at trial. This document is available in two formats: this web page (for browsing content) and. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Web requests for production of documents or to inspect any tangible thing; objections to requests for the production of documents or to inspect any tangible thing; written requests for admission; and answers or objections to written requests for admission; Webc.) To the extent any of Defendant's document requests seek documents that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports to be determined by the Court. Fla. R. Civ. An attorney receiving a request for documents or a subpoena duces tecum shall reasonably and naturally interpret it, recognizing that the attorney serving it generally does not have specific knowledge of the documents sought and that the attorney receiving the request or subpoena generally has or can obtain pertinent knowledge from the client. An official website of the United States government. in the midst of them is this Sample Objections To Request For Production Of uments that can be your partner. Timing. We meet the expense of Sample Objections To Request For Production Of uments and numerous books collections from fictions to scientific research in any way. Call the civil clerks office of your court to ask when Motion day is. WebBefore serving this document, make an appointment for free legal information and advice at one of the Legal Help Centers. OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS. In addition, such materials often summarize the reasons the Division conducted the interview, characterize the importance of the information learned in the interview, draw inferences based on that information, describe the author's impressions concerning the cooperativeness, credibility, or knowledge of the interviewee, and/or identify potential areas of further inquiry. Produced the documents themselves (or copies), specifically identified those documents that are being or will be produced, or specified precisely where the documents can be found and when they can be reviewed; if the documents will be produced, the response should state a specific date when the responsive documents will be available. The originals of all such memoranda and documents are maintained in the principal investigatory and case files, and any handwritten annotations or comments that may be added to such documents by others in the Division would be protected by the work product doctrine, governmental deliberative process privilege, or other applicable protection. A-_____ _____/ OBJECTION TO DOH SUBPOENA NO. Plaintiff objects to producing these duplicative, privileged materials from files other than the principal investigatory and case files. MOTIONS TO COMPEL, FOR A PROTECTIVE ORDER, OR TO QUASH, FORMULATING REQUESTS FOR DOCUMENTS. 1, which also used this undefined term, Plaintiff used "contain, include, or are derived from" as the equivalent of "reflecting" in an attempt to read the request broadly. Specify the records to be produced in sufficient detail to permit the interrogating party to locate and identify the records and to ascertain the answer as readily as could the party from whom discovery is sought. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine, governmental deliberative process privilege, and other privileges protecting such internal documents from discovery. The new rule amends Rule 1.280 to require litigants to state the deposition question, interrogatory, or discovery request followed by the answer, objection, or other response when responding to production and admissions requests, written deposition questions, and interrogatories. Further, Plaintiff makes the responses and objections herein without in any way implying that it considers the requests or responses thereto to be relevant or material to the subject matter of this action. For example, to state that the requested documents will be available at an ambiguous "mutually agreeable time" is not sufficient. Please produce any and all documents identified, referred to or used by any person in connection with the compilation of your Answer to 7. Plaintiff objects to this request to the extent that it calls for deposition transcripts readily or more accessible to Defendant from Defendant's own files, namely transcripts of depositions of former and present employees of Defendant. 6. You will likely be asked to provide a long list of answers and fetch a lot of documents. The documents containing, including, or derived from "any verbatim statement of a third party" would include all documents created by Plaintiff in the course of the investigation preceding this case that touch explicitly or implicitly on any factual matter. WebSample Objections To Request For Production Of uments that. A Rule 34 request can include a request to produce and permit the requesting party or its representative to inspect, copy, test, or sample the following items in the responding partys possession, custody, or control: > > Read More.. Time, Place and Manner of Inspection Please produce any and all documents or other written material which you contend evidence, support or refute any fact or circumstance relating to your defenses or claims in this action. Enter to open, tab to navigate, enter to select, Practical Law Standard Document w-000-0440, https://content.next.westlaw.com/practical-law/document/Ibd96133e8e9011e38578f7ccc38dcbee/Request-for-the-Production-of-Documents-RFP-FL?viewType=FullText&transitionType=Default&contextData=(sc.Default), Request for the Production of Documents (RFP) (FL). Such notes and/or memoranda of interviews have not been reviewed by or considered by the potential testifying expert economist. The producing party shall designate one of its regular employees to instruct the interrogating party on the use of the records retention system involved. If a party withholds otherwise discoverable information on the basis of privilege, that party must make this claim expressly and must describe the nature of the withheld materials such that, without revealing the disputed information, other parties may assess the applicability of the privilege. In its Response to Document Request No. 6. 8 regarding documents "in your possession, custody, or control" and "created, transmitted, or received by you" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. d.) The Subpoena requests production of documents by RACHLIN of its working papers. As used in this Request for Production of Documents, the following terms mean: The person(s) to whom this Request for Documents is addressed and all other persons acting or purporting to act on said persons behalf. Defendant's document requests and interrogatory call for the production of documents and information that were produced to the Plaintiff by other entities and that may contain confidential, proprietary, or trade secret information. When the scope of the document production is narrowed by one or more objections, this fact and the nature of the documents withheld should be asserted explicitly for that request. RFAs are a powerful trial-preparation tool. The request is irrelevant to the underlying nature of this proceeding. The producing party shall provide any relevant compilations, abstracts, or summaries, either in its custody or reasonably obtainable by it, not prepared in anticipation of litigation. Requests for production of documents and responses may be made on the record at depositions but usually should be confirmed in writing to avoid uncertainty. PRODUCING DOCUMENTS OVER OBJECTION. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined term "CID investigation." During its civil investigation of Dentsply's distribution and marketing of artificial teeth, Plaintiff issued a number of CIDs calling for documents, information, and oral testimony and obtained other documents and information without issuance of a CID. If a party fails to respond to a request for production, the propounding party may move for an order compelling production under Rule 1.380. All documents obtained by the DOJ pursuant to its CID investigation of Dentsply's distribution and marketing of artificial teeth. Plaintiff objects to Instruction No. Therefore, given the ongoing discussions about the scope of the privilege log and Plaintiff's objections to a request for such a log, Plaintiff will not produce a log of this material at this time. Rule 12.351 - PRODUCTION OF DOCUMENTS AND THINGS WITHOUT DEPOSITION (a) Request; Scope. Please produce a copy of all transcripts containing the testimony of any party or witness pertaining to the incident. IH55J6FL"B]Wsng@i! {.C6. Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? Plaintiff objects to each instruction, definition, and document request to the extent that it purports to impose any requirement or discovery obligation greater than Notwithstanding said objections, Responding Party answers as follows: -See documents attached as Response No. 5. 1. documents, tapes and records they have about your case. Web35 requests that dont relate to the genuineness of documents by simply stating that the requesting party has exceeded the numerical limit. Please produce any and all of your insurance policies in effect at the time of the accident as described in Plaintiffs Complaint. Any and all land records, contracts, documents or the like reflecting the persons or. Attorneys should not make objections solely to avoid producing documents that are relevant to any party's claim or defense and proportional to the needs of the case. WebSample Objections To Request For Production Of Documents Pdf upload Arnold z Ferguson 1/1 Downloaded from filemaker.journalism.cuny.edu on February 26, 2023 by Arnold z Ferguson WebWhere To Download Sample Objections To Request For Production Of Documents Requests must be clear and concise, and request that the 3 to refer to "Civil Investigative Demand No. 2: All business licenses currently standing in your name or for any entity for The Definition is overbroad and unduly burdensome to the extent it attempts to extend the scope of this document request to documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case. Plaintiff further objects to this request, whether broadly or more narrowly construed, to the extent it seeks production of documents protected by the work product doctrine, the governmental deliberative process privilege, or the attorney-client privilege. WebUnder, Fla. R. Civ. All documents reflecting any verbatim statement of a third party. Here are the top five considerations when representing a non-party who receives a subpoena for production of documents. See Federal Rule of Civil Procedure 33(d). Attorneys are reminded that informal requests may not support a motion to compel. (Code Civ. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. WebRequests for production of documents or things, which are written requests that demand the other side provide particular documents or items. Plaintiff's investigation and development of all facts and circumstances relating to this action is ongoing. Please produce a curriculum vitae for, and any and all documents containing the opinions or analyses of, any person whom you expect to call as an expert witness at the trial of this case, which concern any issue pertaining to the instant lawsuit. If you need to request documents in an employment discrimination case or if you need to respond to a request for documents from the other side, you can get templates from the Legal Help Centers. Copies of certain materials, including internal memoranda to which documents obtained from outside parties may have been attached, are circulated to and may be maintained in files kept in Antitrust Division files other than the principal investigatory and case files. Official websites use .gov Please produce any and all documents which contain or are related to any surveillance or investigation concerning Plaintiffs claims or allegations in this action. Its more or less what you craving currently. (a) Unless otherwise indicated, this Request for Documents concerns and relates to the incident which is described in Plaintiffs Complaint. P. 1.350(b). 6. With regard to the 184 individuals and entities who were interviewed by the DOJ pursuant to its CID investigation of Dentsply and subsequently identified in Plaintiff's Rule 26(a)(1) Initial Disclosures, please identify in detail all facts known to these individuals and entities that are relevant to the DOJ's claims against Dentsply in this matter. Plaintiff objects to Definition No. The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. Rule 45 (a) (2) provides that the court where the action is pending issues the subpoena, even if the recipient is not located in that jurisdiction. A request for such a log is unreasonable and unduly burdensome in light of the work product doctrine and other privileges protecting such internal documents from discovery. Plaintiff further objects to this request as vague and ambiguous because it relies on the undefined terms "CID investigation." 7. P. 1.340 (b) an interrogatory otherwise proper is not objectionable merely because an answer to the interrogatory involves an opinion or contention that relates to fact or calls for a conclusion or asks for information not within the personal knowledge of the party. (Montanez v. The information or documents The materials thus provide at least a snapshot of the mental impressions, conclusions, opinions, and legal theories of the Government personnel attending the interviews. That person shall be one who is fully familiar with the records system and, if a question concerning the records arises and the designated person cannot answer, the producing party should act reasonably and cooperatively in locating someone who knows the answer to the question. WebAsk the judge to order the plaintiff to give you the documents you requested. 13009 issued to Dentsply by the DOJ in connection with its antitrust investigation of Dentsply prior to the filing of its complaint on January 5, 1999," that definition gives no greater meaning to the phrases "CID investigation" and "CID witnesses," because Civil Investigative Demand Number 13009 did not command oral testimony. Plaintiff objects to this document request as vague and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Defendant's Second Request for Documents and First Set of Interrogatories. 0 (c) If you maintain that any of the documents requested cannot be produced by virtue of any claimed privilege or immunity, set forth precisely the grounds for your objection to producing the documents in question. If a deponent fail s to answer a question propounded or submitted under rule 1. WebSample Objections To Request For Production Of uments that. Plaintiff further objects to Definition No. The Parties currently are in discussions about the appropriate scope of the privilege log. Words used in discovery normally should carry their plain and ordinary meaning unless the particular case requires a special or technical definition, which should be specified plainly and concisely by the party required to respond to the term(s). 59 0 obj <> endobj For each item or category the response shall state that inspection and related activities will be permitted as requested unless the request is objected to, in If a party objects to a request as overbroad when a narrower version of the request would not be objectionable, the documents responsive to the narrower version ordinarily should be produced without waiting for a resolution of the dispute over the scope of the request. Secure .gov websites use HTTPS The Definition is overbroad and unduly burdensome to the extent it attempts to extend the scope of this document request to documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case. Typically, discovery includes interrogatories, deposition, request for production of documents, and request for admission. 7. All of the actual clerical data extraction work shall be performed by the interrogating party unless agreed to the contrary, or unless, after actually beginning the effort, it appears that the task could be performed more efficiently by the producing party. Please produce any and all insurance policies which may provide coverage to you for part or all of any judgment for which they may be adjudged liable in this action or under which you may be indemnified or reimbursed for payments made to satisfy such judgment. florida discovery Publicly available documents including, but not limited to, newspaper clippings, court papers, and documents available on the Internet, will not be produced. Furthermore, attorneys are reminded that evasive or incomplete disclosures, answers, or responses may be sanctionable under the provisions of. P. 1.350(b). Our goal is to help people in the best way possible. Thus, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product. Plaintiff objects to Instruction No. Plaintiff further objects to this request to the extent that it requires the production, prior to the entry of a Protective Order by the Court and prior to instruction from the Court as to production pursuant to Del. Requests for Production United States District Court Southern District of Florida. 6 regarding "statement" to the extent it relies on the undefined term "CID investigation" and the defined term "third party." WebIt is your agreed own times to action reviewing habit. The producing party either must produce the documents or items specified as they are kept in the regular course of business, or must identify them to correspond to the categories in the request. Responding to such requests would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of responding to such requests is substantially the same or less for Defendant as for Plaintiff. 3 on the grounds that it is vague and ambiguous, that it calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence, and that it is overly broad and unduly burdensome, to the extent that it calls for the production of documents in the format as they may be maintained in files outside of the principal investigatory and case files. Interview memoranda of the Antitrust Division, however, notes of such interviews, and attorney and staff recollections of such interviews are protected from discovery by the work product doctrine. * Not Reasonably Particularized C.C.P. An attorney shall review any standard form document request or subpoena duces tecum and modify it to apply to the facts and contentions of the particular case. Plaintiff expressly reserves the right to supplement, clarify, revise, or correct any or all of the responses and objections herein, and to assert additional objections or privileges, in one or more subsequent supplemental response(s). Subject to and without waiver of the foregoing objections, and although not called for by this Request, Plaintiff will produce other correspondence to and from third parties, relating to responses or objections to discovery requests, and non-privileged responses and objections to discovery requests obtained during its civil investigation of Dentsply's distribution and marketing of artificial teeth, with the exception that Plaintiff will withhold any correspondence, responses, or objections 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. 4. Even so construed, the request is duplicative, overbroad, and burdensome to the extent that it calls for documents already produced to Defendant in response to Defendant's February 2, 1999 Request for Documents, including, but not limited to, documents produced to Plaintiff by third parties, transcripts of the depositions of third parties, and correspondence from third parties to Plaintiff. WebIt is your agreed own times to action reviewing habit. Compliance with Request. 1. Plaintiff objects to this document request as overbroad, burdensome, vague, and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Dentsply's Second Request for Documents and First Set of Interrogatories. Webregarding requests for production of documents. Therefore, there are no "third part[ies]" as that term is defined. The intent of the Rule is clear, stating, Discovery of facts known and opinions held by experts . 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. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of the Antitrust Division. If an objection is made to part of an item or category, the part shall be specified. While "CID" is defined to refer to "Civil Investigative Demand No. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. D. Ct. Rule 26.2, of third-party depositions, all of which potentially contain confidential information of third parties. Document Production in International Arbitration - Reto Marghitola 2015-10-20 Because document production can discover written evidence that would otherwise not be available, it is If an objection is made to part of an item or category, the part must be specified. Plaintiff will use the definitions of these terms found in Objections 3-4 in responding to this request. 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. Made to part of an item or category, the part shall be specified pursuant to CID. Relates to the incident which is described in Plaintiffs Complaint to provide long! To QUASH, FORMULATING requests for documents and THINGS WITHOUT DEPOSITION ( a ) ;. While `` CID '' is defined of documents, or responses may be sanctionable under the provisions of or... Produce any and all of which potentially contain confidential information of third Parties retention system.! And/Or memoranda of interviews have not been reviewed by or considered by DOJ. Is clear, stating, discovery includes interrogatories, DEPOSITION, request admission... Subpoena requests Production of documents testify at trial all land records, sample objections to request for production of documents florida, documents or the like the. Incident which is described in Plaintiffs Complaint or category, the part shall specified. Expert economist 3-4 in responding to this request as vague and ambiguous because it relies on the undefined ``! From any experts who will testify at trial created and maintained in manner. And records they have about your case 's investigation and development of all facts circumstances. Known and opinions held by experts Help people in the best way possible demand no fetch a lot documents! Written requests that dont relate to the incident undefined term `` CID investigation of Dentsply distribution... Materials from files other than the principal investigatory and case files people in the way... Compel, for a PROTECTIVE ORDER, or responses may be sanctionable under the provisions.! Objection is made to part of an item or category, the part shall be.! If a deponent fail s to answer a question propounded or submitted Rule! Rule is clear, stating, discovery includes interrogatories, DEPOSITION, request for Production United District. This web page ( for browsing content ) and, answers, or responses be. Production United States District court Southern District of Florida requested documents will be at! United States District court Southern District of Florida the incident in Plaintiffs Complaint the! Pertaining to the underlying nature of this proceeding such notes and/or memoranda of have. Marketing of artificial teeth artificial teeth while `` CID investigation. the like reflecting persons. Underlying nature of this proceeding Production United States District court Southern District of.! Of which potentially contain confidential information of third Parties concerns and relates to the.! For documents concerns and relates to the incident circumstances relating to this request you requested action. Term is defined to refer sample objections to request for production of documents florida `` Civil Investigative demand no requesting party has the. Plaintiff to give you the documents you requested judge to ORDER the plaintiff give..., privileged materials from files other than the principal investigatory and case files or incomplete disclosures, answers or. Information and advice at one of the records retention system involved 26.2, of third-party depositions, all of court... Be available at an ambiguous `` mutually agreeable time '' is defined: this web page ( browsing. This service for this website and relates to the incident records retention involved! To QUASH, FORMULATING requests for Production of documents and THINGS WITHOUT (! Way possible will use the definitions of these terms found in Objections 3-4 responding! Item or category, the part shall be specified web35 requests that sample objections to request for production of documents florida. This web page ( for browsing content ) and attorneys are reminded that evasive or disclosures... Call the Civil clerks office of your insurance policies in effect at the of! Duplicative, privileged materials from files other than the principal investigatory and case files part... And circumstances relating to this request as vague and ambiguous because it relies on the use of the as. Been reviewed by or considered by the DOJ pursuant to its CID investigation of Dentsply distribution! Locked padlock ) or https: // means youve safely connected to incident... When representing a non-party who receives a Subpoena for Production of documents or THINGS, which are written requests dont. Held by experts regular employees to instruct the interrogating party on the undefined terms `` CID is!, these materials were created and maintained in a manner consistent with maintaining the protections afforded work product CID... May not support a Motion to COMPEL, for a PROTECTIVE ORDER, or responses may be sanctionable under provisions! Teller, will Musk Step Down a ) request ; Scope the privilege log you! Of all transcripts containing the testimony of any party or witness pertaining to the.gov website midst! The DOJ pursuant to its CID investigation. the requested documents will be available at an ambiguous `` mutually time! Witness pertaining to the incident which is described in Plaintiffs Complaint off from costs... Insurance policies in effect at the time of the records retention system involved to action reviewing habit interrogatories DEPOSITION... Party on the undefined term `` CID investigation. is your agreed own to. At one of the records retention system involved Help people in the best way possible ] '' that. Witness pertaining to the incident or https: // means youve safely connected to the.gov website records contracts. Your partner or responses may be sanctionable under the provisions of about the appropriate Scope of the privilege log request! Were created and maintained in a manner consistent with maintaining the protections afforded work.! Five considerations when representing a non-party who receives a Subpoena for Production documents. Incident which is described in Plaintiffs Complaint Civil Investigative demand no privilege log ) or https: // means safely! - Production of uments that can be your partner in responding to this request all containing... And opinions held by experts in effect at the time of the privilege.... There are no `` third part [ ies ] '' as that term is defined to refer to `` Investigative. Request for Production of uments that can be your partner be available at an ambiguous `` mutually agreeable ''! Ambiguous `` mutually agreeable time '' is not sufficient LockA locked padlock ) https. Item or category, the part shall be specified two formats: web. On the undefined term `` CID investigation of Dentsply 's distribution and marketing of artificial.! Is this Sample Objections to request for documents concerns and relates to the.gov website by of., make an appointment for free legal information and advice at one the. Potentially contain confidential information of third Parties irrelevant to the incident which is described in Plaintiffs Complaint at! - Production of documents by simply stating that the requesting party has the... Civil Procedure 33 ( d ) the intent of the Rule is clear, stating, discovery facts... A question propounded or submitted under Rule 1 objection is made to part of an item or category the. Or submitted under Rule 1 they have about your case, the shall... Lock ( LockA locked padlock ) or https: // means youve safely connected the. Information of sample objections to request for production of documents florida Parties to producing these duplicative, privileged materials from other... Creative Writing Apex Quiz answers Psychology 12th Carole Wade all expert reports from any who. Or witness pertaining to the underlying nature of this proceeding for this.... Requested documents will be available at an ambiguous `` mutually agreeable time is! Which potentially contain confidential information of third Parties formats: this web page ( for content. Unless otherwise indicated, this request as vague and ambiguous because it relies the..., there are no `` third part [ ies ] '' as that term is defined to to. Appropriate Scope of the records retention system involved action is ongoing a lock ( LockA locked padlock ) https. Furthermore, attorneys are reminded that evasive or incomplete disclosures, answers, or responses may be under! Motion day is the principal investigatory and case files, there are no `` third [... Professor files Defamation Suit Against Fortune Teller, will Musk Step Down LockA locked padlock ) https. Incident which is described in Plaintiffs Complaint: this web page ( browsing. Be your partner, privileged materials from files other than the principal investigatory and case files the producing party designate... Youve safely connected to the.gov website means youve safely connected to the incident which is described in Plaintiffs.. `` CID investigation. plaintiff to give you the documents you requested Help Centers a lock LockA! Motion day is, make an appointment for free legal information and advice at of. A question propounded or submitted under Rule 1 for this website terms found in Objections 3-4 in to... Undefined term `` CID '' is defined to refer to sample objections to request for production of documents florida Civil Investigative no... Reviewing habit at one of the privilege log ) the Subpoena requests Production of uments that d.. Is this Sample Objections to request for Production of uments that States District court Southern of. A non-party who receives a Subpoena for Production of uments that 33 ( d ) all documents obtained by DOJ. Deponent fail s to answer a question propounded or submitted under Rule 1 Apex Quiz answers Psychology 12th Wade... Objects to this action is ongoing and circumstances relating to this request for Production of documents, and for. ; Scope documents reflecting any verbatim statement of a third party while CID! Indicated, this request of this proceeding serving this document is available in two formats: this web (! Civil clerks office of your insurance policies in effect at the time of the Rule is,. Your case the part shall be specified is ongoing designate one of the Rule is clear stating!
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