RESPONSE TO CONTENTION INTERROGATORY NO.2: Palmdale objects to this interrogatory on the grounds that it is vague and ambiguous as to the terms "restricted" and "constrained." Palmdale further objects to this interrogatory on the grounds that it is compound. Subject to and without waiving the foregoing objections, Palmdale responds as.An interrogatory is not objectionable 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 it not be answered until discovery is completed. Rule 33; F.T.C. v. Ivy Capital, Inc., No. 2:11-CV-00283-JCM, 2012 WL 1883507, at 5 D. Nev. May 22, 2012. Argumentative— Objection. This discovery request as phrased is argumentative. It requires the. FOURTH DCA OVERRULES WORK PRODUCT OBJECTIONS TO CONTENTION INTERROGATORIES. Compelling meaningful responses to contention interrogatories seeking the basis for a party’s contentions in its complaint or affirmative defenses often meets mixed success. “general objections” at the beginning of the response and then incorporating the objections into each response “to the extent they apply.” Second, by interposing a litany of boilerplate objections to each discovery request and then answering the request “subject to and without waiving” the. Each interrogatory shall be answered separately and fully in writing under oath, unless it is objected to, in which event the reasons for objection shall be stated in lieu of an answer. The answers are to be signed by the person making them, and the objections signed by the attorney making them. The party submitting the interrogatories may move for an order under Rule 4:12a with respect to any objection to or other.
the interrogatory involves an opinion or contention that relates to fact or the application of law to fact, but the court may order that such an interrogatory need not be answered until after designated discovery has been completed or until a pre-trial conference or other later time.” While this rule has more direct application to a defendant. Basic Discovery Objections to Interrogatories and/or Requests for Production 1 Plaintiff/Defendant objects to this [specific discovery, i.e., Interrogatory, Request for Production, etc.] to the extent it seeks information outside of the scope of permissible discovery under the TRCP. or "contention." All should be treated as functional equivalents and objected to by the attorney defending the deposition. Rather than parsing Rifkind into its vari ous.components to derive some discrete, otherwise established objections - and thereby risk the possibility of asserting the "wrong objection'' - the objection. PLAINTIFF'S RESPONSES AND OBJECTIONS TO DEFENDANT'S SECOND REQUEST FOR DOCUMENTS AND FIRST SET OF INTERROGATORIES. Plaintiff, by and through its attorneys, and pursuant to Rules 33 and 34 of the Federal Rules of Civil Procedure and the Local Rules of this Court, responds and objects to Defendant Dentsply International, Inc.'s "Dentsply. [6b] The bonding company's objection that the interrogatory is "ambiguous" and "unclear," is without merit, and the respondent court in sustaining the objection on a different ground apparently recognized this. However, the court's basis for sustaining the objection, that it was a "shot gun question and in effect seeks to have the defendant divulge its entire theory of defense," is equally unsupportable.
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. The undersigned hereby certifies that a copy of the foregoing Defendants' Responses and Objections to Plaintiff's First Set of Interrogatories was served, by regular U.S. mail, postage prepaid, upon Robert A. Neinast, Plaintiff, 8617 Ashford Lane, Pickerington, Ohio 43147, this 26th day of August, 2004.
ambiguous, and overly broad, but “State all facts which support the contention in your Answer that the ASKING PARTY was responsible for the accident alleged in the Complaint,” would be more likely to yield a response rather than an objection. • Remember that special interrogatories are questions requesting written answers, and cannot. Become a member and get unlimited access to our massive library of law school study materials, including 646 video lessons and 4,600 practice questions in 1L, 2L, & 3L subjects, as well as 15,900 case briefs keyed to 215 law school casebooks.
A response must include the party's answers to the interrogatories and may include objections and assertions of privilege as required under these rules. c Option to produce records. Each objection must be followed by a statement of reasons. When an objection is made to part of an interrogatory, the remainder of the interrogatory must be answered at the time the objection is made, or within the period of any extension of time to answer, whichever is later. LR 33-3 Motions to Compel See Fed. R. Civ. P. 33b and LR 37. 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. b Answers and Objections. 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. b Answer and objection. employee identified in Interrogatory No. 5 committed a discriminatory act, reprisal or otherwise engaged in a prohibited personnel practice. OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. Without waiving any.
your contention, set forth in the Answer as Affirmative Defense No. 4, that "Defendant Massa lacks sufficient personal involvement. "Objection: Defendant objects to Interrogatory Number 22, Qualified immunity is a legal argument and not a proper question for individual defendants. How to present a losing objection: 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.
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