List of Documents to be filed in court, including objection to product documents and explanation on why certain documents are missing.
The following is a list of the documents relating to the matters in question in this action which are or have been in the possession, custody or power of the above-named.
The [PARTY] has in his possession, custody or power the documents relating to the matters in question in this action enumerated in schedule 1 hereto.
The [PARTY] objects to produce the documents enumerated in part 2 of the said schedule 1 on the ground that [insert the grounds of objection, e.g. legal professional privilege].
The [PARTY] has had, but has not now, in his possession, custody or power the documents relating to the matters in question in this action enumerated in schedule 2 hereto.
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