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When Can a Party Refer to Produced Records as an Answer to an Interrogatory?

E-Discovery LLC

Plaintiff contended that, in response to plaintiffs interrogatories, Defendants improperly refer to hundreds of pages of documents, which is non-responsive, evasive, and in violation of Federal Rule of Civil Procedure 33(d). First, it must show that a review of the documents will actually reveal answers to the interrogatories.

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Privilege Log Entry Was Relevant to Inquiry Notice Where Time-Bar Was at Issue

E-Discovery LLC

In Cáceres, privilege log entries appeared to show that plaintiffs were on notice of their claim months earlier than they asserted in interrogatory answers. In Connor , privilege log entries were inconsistent with a litigant’s testimony about when termination was first discussed.

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Requests for Documents “Sufficient to Show,” Instead of “Any and All” Documents

E-Discovery LLC

Another suggestion is that: “Limitation of the inquiry to ‘material’ and ‘principal’ facts, as opposed to ‘all’ facts makes the interrogatory acceptable in form.” 20, 2021), a party requested “[d]ocuments sufficient to disclose” annual revenue. Grimm (ret.), Charles Fax, and Paul Sandler, “Maryland Discovery Problems and Solutions” (Md.

Discovery 130
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Court Held That an ESI Protocol Applied Only to ESI

E-Discovery LLC

On a separate issue, Plaintiffs argued that defendant improperly objected to certain standard interrogatories provided by the South Carolina Rules of Civil Procedure. Standard interrogatories generally provide a safe harbor for the discovering party and the Skeans court ordered amended responses. Emphasis in original].

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Trellis Launches Trellis AI to Streamline Trial Court Litigation

Key Witnesses — Identify the people involved in the case and their roles to inform decisions about document requests, interrogatories, and depositions. Analyze Argument — Pinpoint the key arguments and evidence within opposing counsel's brief to help you draft a reply and prepare for a hearing. Want to learn more?

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Spoliation Discovery Permitted

E-Discovery LLC

The court permitted spoliation interrogatories. Plaintiffs supplemental response stated: Plaintiff objects to this interrogatory as compound. Defendants Interrogatory No. Plaintiffs supplemental response stated: Plaintiff objects to this interrogatory as compound.

Discovery 130
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Sometimes Discovery Disputes Do Not Bring Out the Best in Us – Part II

E-Discovery LLC

The main topic here is ‘contention interrogatories’…. Obviously, after years of government investigation and years of discovery, no one can say the contention interrogatories at issue here are premature.” The court explained that: “A large portion of the parties’ dispute has to do with what a contention interrogatory can ask for.

Discovery 130