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

E-Discovery LLC

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.

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

E-Discovery LLC

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 130
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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. Canales may not rely on this objection and must supplement his responses to provide any documents or information withheld on this basis.

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When is Failure to Provide a Timely Privilege Log Excusable?

E-Discovery LLC

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.,

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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. 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.