Objections and Pleadings - Trial Strategy Today

Objections

Pleadings

Decision on How to Best Search for ESI – Court Orders ESI Protocol in “Epic of Dysfunctional Discovery,” With Unique Clawback Provision

E-Discovery LLC

JULY 23, 2025

16, 2024)(“To impress upon them the gravity of the claims they made in their pleadings, the court put both [plaintiff’s counsel] West and [new defense counsel] Goetzl under oath.”). Sometimes Discovery Disputes Do Not Bring Out the Best in Us (Apr. 10, 2024); see also Counsel Not Required to Swear to Having Met Discovery Obligations (Jan.

Discovery

Discovery Affidavits Litigation Objections

Court’s Use of a Special Master to Assist EEOC in Obtaining Discovery from Defendant

E-Discovery LLC

JULY 30, 2025

It appears from the docket that on July 21, 2025, Genesh filed an objection to the Magistrate Judge’s order on this issue. The court finds defendant has not met the high burden for striking pleadings, and the court declines the request to strike material from its docket.” Opportunity Comm’n v. Genesh, Inc., Docket No.

Discovery

Discovery Subpoenas Depositions Mediation

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E-Discovery 101 – – A Refresher on the Scope of Discovery + Boilerplate Objections Sustained

E-Discovery LLC

SEPTEMBER 16, 2024

It – surprisingly – sustained boilerplate objections. While construing relevance broadly, this Court is anchored by the parties’ pleadings. “To Interestingly, the Ho court sustained what appear to be boilerplate objections that plaintiff’s requests were “overly burdensome” and “irrelevant….” The case involved a loan gone south.

Discovery

Discovery Objections Interrogatories Pleadings

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Too Busy to Respond to Discovery = Waiver of Objections & Sanctions

E-Discovery LLC

NOVEMBER 1, 2024

The court wrote: HKS has filed a response, in which HKS does not contest any of Orlando Health’s assertions, admits it has not produced responsive documents, and does not address any objections…. All objections to the discovery at issue, other than privilege, have been waived by the failure to timely respond to the discovery.”

Discovery

Discovery Objections Pleadings Litigation

Deposition Prep Like a Pro: Insights from a Paralegal's Playbook

Speaker: Kaitlyn "The Persnickety Paralegal" Story

Key Learning Objectives: Control the Cadence of the Case 🕒 Learn how to effectively manage and control the flow of your case by ensuring that the timing of the deposition aligns with the specific needs of each case and the preferences of the attorney.

Depositions

Counsel Not Required to Swear to Having Met Discovery Obligations

E-Discovery LLC

JANUARY 4, 2025

However, since a discovery request, response, or objection usually deals with more specific subject matter than motions or papers, the elements that must be certified in connection with the former are spelled out more completely. It might have been preferable to add Fed.R.Civ.P. Like Hall , in Kyle Rayome v.

Discovery

Discovery Pleadings Objections Litigation

The Essential Purpose of Legal Writing: Importance, Types & Strategies

Legal Writing Launch

OCTOBER 4, 2024

We will address: The Importance of Legal Writing in the Legal Profession Understanding the Types of Legal Writing Key Objectives and Functions of Writing Essential Legal Writing Skills and Techniques Strategies for Effective and Persuasive Legal Writing Legal writing stands as the cornerstone of the legal profession.

Objections

Objections Pleadings Precedent Legal Arguments

Two Recent Decisions Imposing Sanctions for Discovery Failures

E-Discovery LLC

DECEMBER 16, 2024

The circuit court ordered Mr. Etame to submit any objections, which he did, with some discovery responses. The circuit court then prohibited Mr. Etame from presenting any evidence and struck his pleadings, including counterclaims. The circuit court found them to be non-responsive and again ordered him to provide specific responses.

Discovery

Discovery Interrogatories Affidavits Pleadings

Three Types of Protective Orders – Requirements to Seal Court Record

E-Discovery LLC

SEPTEMBER 27, 2024

addresses sealing of filed documents: Any motion seeking the sealing of pleadings, motions, exhibits, or other documents to be filed in the Court record shall include (a) proposed reasons supported by specific factual representations to justify the sealing and (b) an explanation why alternatives to sealing would not provide sufficient protection.

Discovery

Discovery Pleadings Exhibits Objections

Another Cinderella Situation –Motion Denied as Untimely?

E-Discovery LLC

MAY 31, 2024

The “Rules of Procedure are the lawyer’s compass and serve to help him [or her] steer through the narrows of pleading, pass the rocks of default, around the shoals of limitation, and safely into the harbor of judgment. 1, 2023)( untimely discovery objection was waived); cf.

Discovery

Discovery Interrogatories Objections Counterclaim

A Request to File a Privilege Log Under Seal Was Denied

E-Discovery LLC

AUGUST 27, 2024

Under the latter rule: Any motion seeking the sealing of pleadings, motions, exhibits, or other documents to be filed in the Court record shall include (a) proposed reasons supported by specific factual representations to justify the sealing and (b) an explanation why alternatives to sealing would not provide sufficient protection.

Exhibits

Exhibits Discovery Privileged Communication Objections

Unopposed Motion to Seal Court Records

E-Discovery LLC

DECEMBER 8, 2024

The latter states: Any motion seeking the sealing of pleadings, motions, exhibits, or other documents to be filed in the Court record shall include (a) proposed reasons supported by specific factual representations to justify the sealing and (b) an explanation why alternatives to sealing would not provide sufficient protection. and 105.11.

Exhibits

Exhibits Pleadings Precedent Objections

Legal Turmoil in the Pharmaceutical Industry: AbbVie, Purdue, and Beyond

Complex Discovery

JULY 12, 2024

Purdue, which pleaded guilty to federal charges related to OxyContin marketing practices in 2007 and 2020, supports the committee’s stance, emphasizing the need for a swift resolution to avoid protracted legal battles. Novartis, however, remains defiant and plans to appeal the decision.

Pharmaceuticals

Pharmaceuticals Settlement Negotiations Mediation Litigation

Word Processing Wars

E-Discovery LLC

JUNE 26, 2024

Another court imposed a limit in the midst of a dispute: “Saber objects to Larkin’s excessive use of footnotes. Defendant’s subjective intent would not be significant if this did not coincide with an objective meaning of ‘chicken.’” One court has a standing order that excessive footnotes will be disregarded. NOSSK, Inc.

Discovery

Discovery Objections Litigation Legal Arguments

Mastering Legal Language: A Guide to Clear and Effective Legal Drafting

Destination Articles Blog

OCTOBER 15, 2024

Introduction The introduction should briefly outline the subject matter, state the document’s objective, and highlight the issues that will be addressed. Detailing these facts accurately and neutrally is crucial to preserving objectivity and credibility. This section prepares the reader for the detailed discussion that follows.

Education

Education Pleadings Legal Precedent Objections

The Complete Guide to Drafting Legal Document Review Protocols

Percipient

SEPTEMBER 29, 2022

A legal document review protocol memorandum will serve as a directing document, stating the review’s objectives, providing case history, reference materials, and coding instructions. A brief synopsis of the case and what the claims are, including key players, can be taken from the pleadings. What is a Document Review Protocol?

Objections

Objections Mediation Pleadings Depositions

Decoding Justice: Key Differences Between Civil and Criminal Litigation

CaseFox

DECEMBER 21, 2023

” Court Hearing Process : Civil cases involve various processes like pleadings, pre-trial motions, trials, and other potential appeals to ensure a fair proceeding. In the emotionally charged landscape of civil disputes, a professional attorney provides objective advice, making merit-based legal decisions.

Litigation

Litigation Evidence Burden Of Proof Objections

Rhymes and Crimes: Fourth Circuit Uses Rap Lyrics as Evidence in Drug Trafficking Case

Practice of Law

SEPTEMBER 5, 2024

Watkins objected to the relevance of these inquiries. Despite Watkins’s objections, the court permitted this line of questioning, concluding that it was relevant to rebut the character evidence presented by Childs. He pleaded not guilty and proceeded to a three-day trial.

Evidence

Evidence Admissibility Objections Pleadings

The Judge REFUSED to Help Us Negotiate & Settle, Forcing Us to Try the Case

Gerry Oginski's New York Legal Blog

OCTOBER 10, 2017

I anticipated making lots of objections, thinking his rulings would favor the defense. Once he gets an idea of what the case is about, he asks for copies of the pleadings. Pleadings are the legal documents that details the allegations against the doctor. I'd never encountered a judge to took that position. This is customary.

Jury Selection

Jury Selection Pleadings Settlement Conference Witnesses

Employer Erred by Downloading Former Employee’s Personal Email; But, Failure to Preserve it Was Not Spoliation; and, There Was a Gap in Employee Handbook Clause Permitting Employer Access Post-Termination

E-Discovery LLC

OCTOBER 6, 2024

The technology consultant was not identified as an expert for either side, but, without objection from Mr. Shapiro, HHI offered the consultant’s affidavits in support of its motion for summary judgment. Thus, it granted summary judgment.

Evidence

Evidence Discovery Litigation Affidavits

A Wake Up Call Revisited: Read the Rules & Don’t Argue “Not Reasonably Calculated” in Federal Courts

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

Interrogatories Objections Discovery Admissibility

Judicial Notice: Four Must-Know Rules

Evidence at Trial

MARCH 22, 2023

In pretrial litigation , judicial notice requests are used in pleadings to establish some needed fact without an attesting witness. First, when taking judicial notice of adjudicative facts, the judge is required to give the parties notice and an opportunity to object to the taking of judicial notice. 201(f); see also Cal.

Evidence

Evidence Witnesses Hearsay Rule Admissibility

Thomas Suh and Ken Block on How LegalMation is Revolutionizing Litigation Efficiency (TGIR Ep. 222)

3 Geeks and a Law Blog

SEPTEMBER 25, 2023

One team does only written discovery one Kim does he does initial pleading stage and one team does the expert depositions as a separate sort of, and then one team of course, that’s the trials. m&s J’s, and they’re, they’re depleted pleadings and everything else that they did was just like poetry. I think that is possible.

Litigation

Litigation Technology Discovery Insurance

Steve Bannon Pleads Guilty to Fraud Charge Over Wall Scam

Practice of Law

FEBRUARY 13, 2025

Bannon pleaded guilty to a single charge of felony scheme to defraud. While the International Boundary and Water Commission raised objections, the biggest problems came from the founders of the fund stealing money for their personal use. While Bannon may have avoided incarceration, the felony fraud he pleaded to will remain.

Pleadings

Pleadings Subpoenas Objections

Colorado Man Indicted for Allegedly Murdering His Wife: Take Two

Practice of Law

JUNE 24, 2025

A vote for Trump cast via mail-in ballot in the 2020 election by the missing wife, which the husband later pleaded guilty to? Cameras also showed him placing unidentified objects in various garbage cans in Broomfield. He pleaded guilty in exchange for avoiding prison through a year of supervised probation.

Forensic Evidence

Forensic Evidence Evidence Pleadings Objections

VEXATIOUS LAWYERING

Temple University Beasley School of Law - Advocacy

MAY 28, 2025

In its responsive pleading, the Government argues that assertions about the supposed illegality of the EO cannot substitute for a showing that they are entitled to extraordinary relief. 2025) But the Government brief cast the pleadings as without basis (having no cause of action), and claims without a valid basis are by definition frivolous.

Pleadings

Pleadings Litigation Evidence Objections

Decision on How to Best Search for ESI – Court Orders ESI Protocol in “Epic of Dysfunctional Discovery,” With Unique Clawback Provision

Court’s Use of a Special Master to Assist EEOC in Obtaining Discovery from Defendant

Webinars

Trending Sources

E-Discovery 101 – – A Refresher on the Scope of Discovery + Boilerplate Objections Sustained

Webinars

Too Busy to Respond to Discovery = Waiver of Objections & Sanctions

Deposition Prep Like a Pro: Insights from a Paralegal's Playbook

Counsel Not Required to Swear to Having Met Discovery Obligations

The Essential Purpose of Legal Writing: Importance, Types & Strategies

Two Recent Decisions Imposing Sanctions for Discovery Failures

Three Types of Protective Orders – Requirements to Seal Court Record

Another Cinderella Situation –Motion Denied as Untimely?

A Request to File a Privilege Log Under Seal Was Denied

Unopposed Motion to Seal Court Records

Legal Turmoil in the Pharmaceutical Industry: AbbVie, Purdue, and Beyond

Word Processing Wars

Mastering Legal Language: A Guide to Clear and Effective Legal Drafting

The Complete Guide to Drafting Legal Document Review Protocols

Decoding Justice: Key Differences Between Civil and Criminal Litigation

Rhymes and Crimes: Fourth Circuit Uses Rap Lyrics as Evidence in Drug Trafficking Case

The Judge REFUSED to Help Us Negotiate & Settle, Forcing Us to Try the Case

Employer Erred by Downloading Former Employee’s Personal Email; But, Failure to Preserve it Was Not Spoliation; and, There Was a Gap in Employee Handbook Clause Permitting Employer Access Post-Termination

A Wake Up Call Revisited: Read the Rules & Don’t Argue “Not Reasonably Calculated” in Federal Courts

Judicial Notice: Four Must-Know Rules

Thomas Suh and Ken Block on How LegalMation is Revolutionizing Litigation Efficiency (TGIR Ep. 222)

Steve Bannon Pleads Guilty to Fraud Charge Over Wall Scam

Colorado Man Indicted for Allegedly Murdering His Wife: Take Two

VEXATIOUS LAWYERING

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