There are a host of different objections than can be raised to discovery requests. They fall generally into the categories of general objections and specific objections.
General objection is made to this discovery request as follows:
- To the extent that the instructions or definitions exceed or are inconsistent with the Rules of the Court, they are objected to.
- All objections as to relevancy, authenticity or other basis for admissibility at trial are preserved.
- To the extent that any of these discovery requests call for documents/information protected by the attorney-client privilege or the attorney work product doctrine they are objected to.
Specific objection is made to this discovery request on the following grounds:
- To the extent that it calls for anything protected by the attorney-client privilege.
- To the extent that it calls for anything protected by the attorney work product doctrine.
- To the extent that it calls for the mental impressions of Counsel.
- To the extent that it calls for anything that is confidential or proprietary.
- To the extent that it calls for anything prepared in anticipation of litigation.
- To the extent that it calls for “all documents” of a specified nature or type when a limited number of documents will provide the requested information, on the grounds that such a requirement makes the request overly broad.
- Not reasonably calculated to lead to the discovery of admissible evidence in that…
- What is sought is equally available to the party making such request.
- Overly broad in that there are no time parameters set, the precise scope of the request is not defined and the information requested is obtainable by less intrusive means.
- Vague, ambiguous or unclear in that…
- Unduly burdensome in that…
- Seeks legal opinions and/or conclusions.
- Beyond the scope of permissible discovery in that…