Legal Question in Civil Litigation in California

Ordinarily, such a request will include a range of dates. If it doesn't, then it means all communications up to the present. In other words, everything up to the moment you sign the responses. Later on they can ask you to update your prior answer with newer information.

If the request doesn't include a date range, there are several objections you may be able to make. Without more specifics, I can't say which (if any) would be appropriate for you to make.

Mr. Hoffman is correct. I would also add that there may be privileges that apply after the lawsuit is threatened or pending that would not apply before that. You would need to have the facts reviewed by competent litigation counsel to figure out if any privileges apply.