Objection Production

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.

ANSWER: A fictional document. A non-existent objection neither based in statutory authority nor found in case law. A statement by a party during the discovery phase that they will neither be held to the Code of Civil Procedure nor the rules of evidence.

Thank you for your inquiry regarding our product or service. Thank you for your interest in our product or service. We would like to thank you for your letter inquiring about our product. We truly appreciate your letter asking for information about our service.

A request for production is a discovery device used to gain access to documents, electronic data, and physical items held by an opposing party in a legal matter. The aim is to gain insight into any relevant evidence that the opposing party holds.

SUMMARY: Failure to timely answer discovery or refusal to answer discovery has two important and potentially catastrophic consequences. You may waive your right to object to the discovery even if the other party has no right to the information requested. In other words, you may be forced to give it to them.

An objection to a. discovery request is boilerplate when it merely states the legal grounds for. the objection without (1) specifying how the discovery request is deficient. and (2) specifying how the objecting party would be harmed if it were. forced to respond to the request.8 For example, a boilerplate objection.

The making available by a party of documents in his possession, custody or power for inspection by the other party or for use as evidence at trial.

If a request asks for a document, make a copy of the document; in your response, describe the document and say that a copy is attached; and attach a copy of the document to the responses you send back to the other side.

When responding to Requests for Admissions, remember to answer as follows: Admit: If any portion of the Request for Admission is true then you must admit to that portion of the request. You are also allowed to have a hybrid response admit the part of the request that is true while denying another part.