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

E-Discovery LLC

The Court pointed out that the right question was found in a standard form interrogatory. 3 (General Interrogatories) (Itemize and show how you calculate any economic damages claimed by you in this action, and describe any non-economic damages claimed. Standard General Interrogatory No. But it was not propounded by Joan.

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

E-Discovery LLC

On a different, rules-based procedural issue, Canales asserted that contention interrogatories, which are permitted by Fed.R.Civ.P. So OPW did not need to wait until a particular point in the proceeding to serve contention interrogatories. .; accord Avila v. Target Corp., 2022 WL 14763013, at *2 (E.D.N.Y. 25, 2022)(quoting Judge Peck).

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CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.