In response to request to production of document, what kind of statement of compliance is required per C.C.P. 55 2031.210, 2031.220, 2031? I produced all the documents before to the other party but they are asking me to produce document "code complaint". Should I produce again?
If I am not objecting to the request but there might be some documents lost or could not be found, would something like "after diligent search and a reasonable inquiry, I produced all the documents that I could found" sufficient?
If I am not objecting to the request and can find all the document, would something like "I produced all documents or things in the demanded category that are in the possession, custody, or control of me and to which no objection was made had been included in the production" sufficient?