Cheat Sheet for Interrogatory and Discovery Objections Plaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly The information or documents will be made available for review at their storage location during business hours at a mutually convenient time
How to Make Objections to a Request for Production Following each request, you will provide your written response, which could be an agreement to produce documents, an objection, or a combination of both If you object, you must state the specific legal reason For example, you would write, “Objection This request seeks information protected by the attorney-client privilege ”
Discovery: Responding to Requests for Production or Inspection Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome The propounding (requesting) party must include enough information to make the requested documents easily identifiable
Practice Guidance: Objections to Discovery Requests - Gavel Standard objections to discovery requests under the FRCP and the Cal CCP, which can be used in other jurisdictions as well In litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories [1]
A. Preparation and Interpretation of Requests for Documents Objections to requests for production should be specific, not generalized, and should be in compliance with the provisions of Rule 34(b), Federal Rules of Civil Procedure Objections to portions of a document request do not excuse the responding party from producing those documents to which there is no objection
Common mistakes and pitfalls in responses to Requests for Production of . . . In short, there are four basic code-compliant responses one must utilize, in whole or in part, for each particular RPD: (1) There will be no production of any documents whatsoever based solely upon a legal objection(s); (2) There will be a production of all documents without any objection; (3) There will be a production of documents, in part
Garbage Objections = Motion to Compel Further Responses and Further . . . The responding attorney must also be careful not to assert objections to requests for production of documents for documents that do not exist or are not in the attorney or party’s possession, custody or control Such a response violates an attorney’s ethical duty under Bus Prof Code §6068(d) to