Legal Question in Civil Litigation in California

It's best to produce them, since they might not have everything you have, or they want to know just what you have and don't have. Of course, if the documents were generated by the asking party (such as an employment or instruction manual), you can object on the basis that it was created by the asking party and the original presumably is within its possession, custody, and/or control, and to produce it would be burdensome, oppressive, and duplicative.

I agree with Mr. Cohen. If ther ae a very lage numbe of pages, you can state that and give a loction where the documents can be examined and copies will be made of whatever is then reasonably requested.

Arguably, you only have to produce for inspection documents that are in your custody or control. I agree with Mr. Cohen, however. You cannot safely assume that the propounding party has the same documents that you have. For example, in a contract dispute, the attorney for the propounding party may be trying to verify that your copy of a written contract matches his copy of a written contract. In that case, your failure to produce the copy of the written contract could subject you to a motion to compel a further response and compliance.

The Discovery Act allows the parties to reduce the factual issues, by determining whether documents in both parties' possession and control are the same, or whether they are different. I have seen situations where a deed or a contract has been altered after execution, and the propounding and responding parties have very different terms. It would not be fair for you to sit back and assume that their documents are the same as yours.

You got a lot of long winded answers. The short answer is that the other side is entitled to see what you have, regardless of whether they have it too. You must produce them.