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Local Rule Prohibiting Definitions in Interrogatories Without Leave of Court

E-Discovery LLC

The court cited a local rule that prohibits use of definitions in interrogatories without leave of court. In pertinent part, Herman objected to the definitions in Payne’s interrogatories. b) (“A party may not separately define words used in an interrogatory without the court’s leave.”). applies only to interrogatories.

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Relative Proportionality Argument Rejected

E-Discovery LLC

Wiegand objected. After setting out the boilerplate on scope of discovery and requirements for a protective order, the Court wrote: “The burden is on the party resisting discovery to explain specifically why its objections, including those based on irrelevance, are proper given the broad and liberal construction of federal discovery rules.”