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

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. at 190, 192.

Objections

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

MAY 12, 2025

Plaintiffs complained that defendants provided only generalized privilege objections in response to discovery. On a separate issue, Plaintiffs argued that defendant improperly objected to certain standard interrogatories provided by the South Carolina Rules of Civil Procedure. Emphasis in original].

Interrogatories

E-Discovery LLC

FEBRUARY 23, 2025

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

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

FEBRUARY 8, 2025

The Court pointed out that the right question was found in a standard form interrogatory. The crux of Joans objection to the disputed claims was that Rebecca did not supplement her responses to discovery by identifying those additional claims for damages. Standard General Interrogatory No. But it was not propounded by Joan.

Interrogatories

E-Discovery LLC

JUNE 20, 2024

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

E-Discovery LLC

AUGUST 16, 2024

The identification of non-custodial sources of data is a foundational issue, and you don’t get to make an objection to the other side’s disclosure and then hold on to that objection forever and ever, and years later ask to start the whole process over from scratch. We’re not starting this over from the beginning. emphasis added].

Discovery

E-Discovery LLC

MAY 31, 2024

8, 2023); Court Uses an Informal Discovery Procedure to Hold That Untimely Objections Were Waived, and Answers to Interrogatories Defectively Referred to Deposition (Nov. 1, 2023)( untimely discovery objection was waived); cf. 14, 2024); Spoliation Motions Denied as Untimely – Another Wake-Up Call (Sep.

Discovery

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. Next , the court overruled the improper boilerplate objections. 26, 2024). _ [1] I will soon be posting an updated blog on boilerplate objections.

Admissibility

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

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

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

FEBRUARY 26, 2025

In the first blog, I suggest that the Li court considered a subjective factor in an objective test. Li to answer interrogatories asking if she or anyone else had deleted or destroyed any information requested in defendants discovery. A second interesting aspect of Li is that the court permitted discovery relating to spoliation.

Discovery

E-Discovery LLC

MARCH 8, 2025

The court wrote that it then adopted Defendants protocol [as an order] and no objection to that order was filed. Mistake #2: Next, Plaintiffs interrogatory responses were untimely and the U.S. See Too Busy to Respond to Discovery = Waiver of Objections & Sanctions (Nov. 2] That objection was timely. See 28 U.S.C.636(b)(1)(fourteen

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

WA Bar News

NOVEMBER 12, 2024

1 The amendments to CR 26 affect objections, supplementation, and disclosure of experts. In response to the objection this might increase costs and introduce ambiguity, the Work Group determined most parties already ask for supplementation, so there is no net increase in work. General objections shall not be made.

Depositions

E-Discovery LLC

SEPTEMBER 4, 2024

Mr. Subrin reports of a pre-1929 case in which 2,258 interrogatories were filed. The defendants’ objection is overruled, and the requested documents are to be produced within the next 14 days. They are not an appropriate basis on which to base a discovery objection. 691, 717 (1998)(citation omitted). emphasis added].

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

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

E-Discovery LLC

JANUARY 15, 2025

Plaintiffs asserted, however, that Defendant insists on keeping its relevant custodians and data sources to itself (or at least forcing Plaintiffs to try and discover the same through interrogatories and depositions). emphasis added]. The Zarfati court then published an ESI Protocol. at *5, passim.

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

The platform also offers 1-Click Objections, making it easy to add, edit, and customize objections with a single click. It leverages AI to suggest and write tailored content, such as Requests for Admission, Requests for Production, and Interrogatories.

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

E-Discovery LLC

APRIL 23, 2025

The District Court expedited its ruling, deciding the issues without a motion to compel: To facilitate the just and expeditious production of discovery, the Court rules on Defendants stated objections included within their answers to Interrogatories and responses to Requests for Production of Documents (RPDs). Emphasis in original].

Discovery