Brien Roche
When developing discovery objections, they will typically fall into one of two categories – general objections or specific objections. The rule and expectation is that your objections be precise. Too often general objections are used. Utilize the right type in your case.
General objections, also known as boilerplate objections, may be of some value. While the rules require objections to be specific to discovery requests, general objections as to attorney-client privilege and work product items may help protect you and the client.
These are some examples of how general objections are used:
Specific objections are more likely to get you the result you’re seeking. The purpose of your objection is to inform opposing counsel and the court that you see a problem with the request and then the objection should inform opposing counsel as to what the nature of the problem is.
Examples of specific objections you can make during discovery include the following:
These objections alone however may not suffice. Therefore if you’re saying that something is vague, you need to give particulars as to why it’s vague. Where you’re saying that it’s equally available to the opposing side, you need to specify. If you’re saying it’s overly broad, you need to specify. Again the emphasis has to be on being specific.
For more support on developing solid discovery objections, contact us to learn how to support you in crafting objections that help things go in your favor.
Call, or contact us for a free consult. Also for more info on discovery objections see the Wikipedia pages. Also see Brien Roche’s book on Objections.