Plaintiff objects to this interrogatory because it seeks information from third parties and information not within its possession, custody, control, or personal knowledge.Instead, it was filed for the purpose of harassing, oppressing, embarrassing and annoying a woman who everyone agrees is a victim by seeking discovery of matters that have zero relevance to this lawsuit. Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence.(Boy, you are behind the 8-ball if this is your answer but we have made this response before.) Plaintiff objects because the answer to this question may violate the defendant's protection against self-incrimination.Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the plaintiff.Federal Rule 26(g), requires parties to consider discovery burdens and benefits before requesting discovery or responding or objecting to discovery requests and to certify that their discovery requests, responses, and objections meet the rule requirements.) (This is usually a defendant's objection, actually. Alternatively, upon request the plaintiff will provide the defendant with an estimate of what it would cost to procure and produce these documents and the parties can agree on the cost of such a production. The information or documents will be made available for review at their storage location during business hours at a mutually convenient time. Plaintiff objects because the identification, photocopying, and production of the requested documents would be oppressively burdensome and costly.Plaintiff objects to this interrogatory because this interrogatory calls for privileged information within the attorney-client privilege that it seeks information that is in the attorney's work product.Therefore, the plaintiff cannot provide an answer. Plaintiff objects to this interrogatory because this interrogatory is so broad, uncertain, and unintelligible that the plaintiff cannot determine the nature of the information sought.It is not the job of the plaintiff to guess what would have happened in an alternative universe. Plaintiff objects because this interrogatory calls for pure conjecture and speculation.Plaintiff objects to this interrogatory because it calls for the plaintiff to make a legal conclusion.Plaintiff objects to this interrogatory as vague, ambiguous, argumentative, overbroad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence.So here are some sample interrogatory objections, a cheat sheet that might help you determine how to object to interrogatories (that can also be applied to other discovery objections): Sometimes, it is hard to come up with the exact words of why you want to object or to match the feeling that the request is objectionable with the appropriate law. Sample interrogatories in all types of personal injury, medical malpractice, and wrongful death cases.or protected by the work product doctrine. These are typically requests that are not relevant, unduly burdensome, broad, vague, privileged. Generally, interrogatories are objectionable if they seek information that is not within the scope of discovery as defined in Maryland Rule 402 or Federal Rule 26(b). Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure." Federal Rule 33(b)(4) emphasizes that the "grounds for objecting to an interrogatory must be stated with specificity. You need to be clear in your objections or risk waving them. The filing of timely discovery objections defers the requirement to answer the question until the defendant objects to your objections. Just like you can take advantage of lazy or distracted lawyers by forcing answers to your interrogatories, you can also gain an advantage by not answering interrogatories that are arguably objectionable. Under Maryland law, this onus is on the party receiving the objection to force the issue. Practically, discovery objections also allow you to avoid answering difficult questions. There are times when you should not give complete answers to an interrogatory because the question is objectionable. If we do not hold defendants' feet to the fire, we toss away a powerful tool to box in defendants for trial - and provide evidence that we are not giving the case the care and attention it deserves.īut this is an adversarial process. This page provides a cheat sheet for discovery objections for lawyers.Įlsewhere on this website, we talk about the importance of forcing defendants to provide meaningful answers to interrogatories, requests for the production of documents, and other discovery responses and requests.
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