discovery responses

RFP responses + privilege log

Written responses to document production requests plus a log of documents withheld on privilege grounds.

When it's used

Within 30 days of service of RFPs and contemporaneously with any production of documents.

Definition

RFP responses are the formal written statements admitting or objecting to each document production request, accompanied by the actual production of responsive documents and, where documents are withheld, a privilege log as required by California CCP §2031.240. The privilege log must identify each withheld document by date, author, recipient, general subject matter, and the specific privilege or protection claimed—without revealing the privileged content itself. The paralegal reviews the client’s documents, categorizes them as produce, redact, or withhold, Bates-stamps the production set, and compiles the log in a spreadsheet format that opposing counsel can evaluate without requiring court intervention. A complete and well-organized privilege log reduces the risk of inadvertent waiver and preempts motions to compel that could force disclosure of protected materials.

Examples in this portfolio