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Rule 33 assures that the objections will lead directly to court, through its requirement that they be served with a notice of hearing.
Rule 33(d) allows a responding party to substitute access to documents or electronically stored information for an answer only if the burden of deriving the answer will be substantially the same for either party.
Make it a lead-off ?general objection.? Object to anything that is not relevant to the ?subject matter? (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection. Use boilerplate wording from form files.
If the question contains several parts, you may break your answer into parts as well. It is also possible that you might object to the question. To raise an objection, you write ?Responding party objects on the grounds? followed by why you object.
Common objections to requests for production or inspection include: The request is overly broad or unduly burdensome. The propounding (requesting) party must include enough information to make the requested documents easily identifiable.
If you are unable to answer a specific question because you don't know or don't have access to the appropriate information, you must indicate the reasons. You may refer to a previous response when responding to an interrogatory providing the previous response sufficiently answers the later interrogatory.
An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact, but the court may order that the interrogatory need not be answered until designated discovery is complete, or until a pretrial conference or some other time.
(1) Application for a new trial shall be made by motion which, except for the cause of newly discovered evidence, shall be filed within fourteen days after the verdict was rendered, or the decision of the court where a trial by jury has been waived, unless it is made to appear by clear and convincing proof that the ...