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

E-Discovery LLC

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. See Reasonably Calculated to Lead to Discovery of Admissible Evidence (Nov. Emphasis added]. citation omitted]. accord Avila v.

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If You Don’t Ask the Right Question, You Won’t Get the Answer

E-Discovery LLC

While not the focus of this blog, it is interesting that some of the evidence of the undue influence came from graphic text messages. The Court pointed out that the right question was found in a standard form interrogatory. Standard General Interrogatory No. But it was not propounded by Joan. Rules Form No.

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Trellis Launches Trellis AI to Streamline Trial Court Litigation

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

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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
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“Boilerplate” Objections Are Generally Condemned; Except When They’re Not

E-Discovery LLC

26(b)(1)states: The former provision for discovery of relevant but inadmissible information that appears “reasonably calculated to lead to the discovery of admissible evidence” is also deleted. It is replaced by the direct statement that “Information within this scope of discovery need not be admissible in evidence to be discoverable.”