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 130

Discovery Objections Interrogatories Pleadings 130

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.,

Interrogatories 130

Interrogatories Objections Discovery Litigation 130

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 130

Admissibility Discovery Objections Interrogatories 130

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].

Interrogatories 130

Interrogatories Discovery Depositions Litigation 130

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 130

Discovery Objections Admissibility Expert Testimony 130

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.

Interrogatories 130

Interrogatories Discovery Counterclaim Objections 130

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.

Interrogatories 130

Interrogatories Discovery Objections Litigation 130