E-Discovery LLC

OCTOBER 9, 2024

27, 2024), “boilerplate” objections were sustained on the specific facts presented. BOILERPLATE OBJECTIONS HAVE GENERALLY BEEN CONDEMNED Boilerplate objections have generally been condemned. See General Objections, Dracula, and “Whac a Mole” (Apr. In Jacobs v. The Journal Publishing Co., 2024 WL 4333199 (D. 168, 170 n.1

Objections

E-Discovery LLC

JANUARY 8, 2025

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.

Interrogatories

E-Discovery LLC

SEPTEMBER 16, 2024

It – surprisingly – sustained boilerplate objections. Interestingly, the Ho court sustained what appear to be boilerplate objections that plaintiff’s requests were “overly burdensome” and “irrelevant….” While boilerplate objections are generally ineffective, see General Objections, Dracula, and “Whac a Mole” (Apr.

Discovery

E-Discovery LLC

AUGUST 16, 2024

In the latest iteration of In Re StubHub Refund Litigation , 2024 WL 3817068 (N.D. This is adversarial litigation, and there need to be clearly understood responsibilities. But that’s not true.” emphasis added]. We’re not starting this over from the beginning. The rest of the decision did not go well for plaintiffs. emphasis added].

Discovery

E-Discovery LLC

JUNE 24, 2024

2010)(emphasis added); see, e.g., Court Excused Party From Waiver by Failure to Provide Specific Objections (Aug. Furthermore, even when privilege objections are timely asserted, the failure to produce a proper privilege log generally constitutes waiver of the privilege objections.” In Bautech USA, Inc. Resolve Equip.,

Objections

E-Discovery LLC

OCTOBER 2, 2024

Defendant Hirschbach added the following to its work product objection: Beyond this, Hirschbach objects to this request because it is overbroad, vague and ambiguous. Plaintiff responded that the videos were not created in anticipation of litigation and therefore they are not protected work product. 9, 2021). [2] 9, 2021). [2]

Admissibility

E-Discovery LLC

FEBRUARY 26, 2025

In the first blog, I suggest that the Li court considered a subjective factor in an objective test. While Sedona correctly states that the test is whether a reasonable party in the same factual circumstances would have reasonably foreseen litigation, I have some questions about the Li Courts conclusion. What facts led Ms.

Discovery

E-Discovery LLC

MAY 31, 2024

The Fiskars court explained that: The bottom line is this: Even if the court were inclined to compel production of source code and related documents, that information would be unusable in this litigation absent a dramatic upheaval of the schedule…. 1, 2023)( untimely discovery objection was waived); cf.

Discovery

E-Discovery LLC

JUNE 20, 2024

Nor is it a positive development when that court wrote: “Things have never exactly moved along at a break-neck pace in this litigation. The main topic here is ‘contention interrogatories’…. The court explained that: “A large portion of the parties’ dispute has to do with what a contention interrogatory can ask for.

Discovery

E-Discovery LLC

SEPTEMBER 25, 2024

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.”

Discovery

E-Discovery LLC

MARCH 8, 2025

Some litigants have refused to enter into ESI Protocols, or refused to agree to incorporate a contractual protocol into a court order, out of concern that a future failure to comply would lead to sanctions. The court wrote that it then adopted Defendants protocol [as an order] and no objection to that order was filed. Emphasis added].

Discovery

E-Discovery LLC

DECEMBER 16, 2024

The circuit court ordered Mr. Etame to submit any objections, which he did, with some discovery responses. Benton filed suit, Hartley Hall propounded interrogatories and document requests. Benton then responded; however, no documents were produced and Hartley Hall asserted that the interrogatory answers were incomplete or unresponsive.

Discovery

WA Bar News

NOVEMBER 12, 2024

1 The amendments to CR 26 affect objections, supplementation, and disclosure of experts. This article will explain the changes effected by the rule amendments and, with respect to CR 26, provide context considered by the Civil Litigation Rules Revision Work Group in drafting the proposed amendments to illustrate their impact.

Depositions

E-Discovery LLC

SEPTEMBER 4, 2024

Discovery is the lawyer’s x-ray: “Discovery procedure serves much the same function in the field of law as the X-ray in the field of medicine and surgery; and if its use can be sufficiently extended and its methods simplified, litigation will largely cease to be a game of chance.” 691, 717 (1998)(citation omitted). Rodriguez v. 7, 2022).

Discovery

E-Discovery LLC

JULY 6, 2024

For example, Sedona suggested that: “Bogging down requests for specific documents with the ‘any and all’ preamble usually serves to draw objections and delay production.” See Requests for “Any and All” Documents Are Obsolete. In Maker’s Mark Distiller, Inc. Spalding Grp., 2021 WL 2018880 at *8 (W.D.

Discovery

E-Discovery LLC

OCTOBER 17, 2024

The court: set out the governing standard for discovery from an attorney and, denied a request to depose the attorney; but, authorized a limited interrogatory to him. The defendants, a Town and others , denied knowledge of the alleged offer. The plaintiffs wanted to develop certain property that they owned. emphasis added].

Discovery

E-Discovery LLC

JUNE 25, 2024

1] __ [1] The court addressed boilerplate objections in detail, id. at *5-6, passim , as well as contention interrogatories, id. It addressed responses to requests for admission and the need for specific objections to document requests. The Norcold court addressed a number of other issues. [1] at *6, among other issues.

Discovery

E-Discovery LLC

AUGUST 13, 2024

The Court “presided over a discovery dispute hearing related to Plaintiff’s motions to compel interrogatory requests and requests for production of documents, and related to a motion for a protective order filed by the Defendant.” 7, 2024)(Simms, J.), plaintiff, acting pro se, sued her employer, alleging discrimination.

Discovery

SW&L Attorneys Blog

MARCH 15, 2025

A failure to provide the requested information without valid objections may result in a motion to compel, a procedural mechanism through which a party seeks judicial intervention to enforce compliance. The opposing party may object to discovery requests by asserting that the information sought is cumulative, duplicative, or unduly burdensome.

Discovery

MyCase

MAY 2, 2024

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Discovery

E-Discovery LLC

FEBRUARY 25, 2025

19, 2025)(Emphasis added), the court wrote: Throughout his responses, Canales objects to OPWs requests on the ground that they are not reasonably calculated to lead to the discovery of admissible evidence. Canales may not rely on this objection and must supplement his responses to provide any documents or information withheld on this basis.

Interrogatories

E-Discovery LLC

JANUARY 29, 2025

21, 2025), the court wrote that: Neither side distinguishes between waiver of untimely objections to interrogatories and waiver of untimely objections to RFPs, even though important differences exist in both the applicable rules of civil procedure and the case law construing them. It held that plaintiffs waived the objections.

Interrogatories