Compound interrogatory objection. 0 series, special interrogatory and production requests.

Compound interrogatory objection Two common objections however—that the interrogatory propounded is either argumentative or In addition to the 13. postmacro2 (do not delete) 6/10/2013 9:36 am ending evasive responses to written discovery: a guide for properly responding (and objecting) to interrogatories and document requests under the texas discovery rules Aug 30, 2021 · The number of interrogatories is further limited by the fact that, according to Texas Rules of Civil Procedure 190. Each objection must be stated separately (no objections to entire set), and must bear the same number or letter as the interrogatory to which it is directed. For example, a Request for Admissions that asks you to admit that your defenses lack merit. that support that objection. 060(f) regarding special interrogatories which states “No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question;” there is no similar statutory limitation regarding requests for production of documents. A party may serve on another party - no later than 30 days before the end of the discovery period -written interrogatories to inquire about any matter within the scope of discovery except matters covered by Rule 195. the objection, we . Proper Discovery Objections To Interrogatories (Form, Special) Ambiguous (only if the question is really unintelligible) [Deyo v Kilbourne (84 CA3d 771, 783)] Compound [CCP § 2030. It provides that deposition testimony will not be excluded on the basis of an improper question unless a seasonable objection to the form of the question is raised during the deposition. Oct 8, 2019 · Boilerplate objections are now more common in response to document requests. 010) and 3 (commencing with Section 2017. Objections must be specific, clearly stating the grounds for each objection. Seeks work product. 28 These questions are “ambiguous and confusing” for witnesses, and so courts generally sustain these objections if the problem is not corrected during the deposition by the questioning attorney after an You have 30 days after the form or special interrogatories were served to you (35 days if served by mail from within California) to serve your responses to the interrogatories. 060, subdivision (d) because each was not “full and complete in itself” was interposed to interrogatory Nos. Also not if a Special Interrogatory necessarily needs to use the word "and" (such as to accurately describe something). J. • No party shall combine in a single document requests for admissions with any other method of discovery (i. 3 (Level II). Most of those objections stem directly from provisions in the Federal Rules of Civil Procedure (“FRCP”). Jul 29, 2010 · General Objections: C. It is the quick-draw nature of many trial permissibly compound. Apr 30, 2021 · An objection is often missed when the interrogatory in question contains subparts or is compound, conjunctive, or disjunctive. [27] The Willamette University School of Law Moot Court Board has a long tradition of promoting the art of appellate and trial advocacy by sponsoring various competitions and providing educational seminars to members and other interested students. Privileged information. Without waiving the objections, Defendant responds that at this time he has not made a determination of which fact or expert witnesses he will present at trial. , § 2030. , opinion, hearsay, assumes facts not in evidence Rule 197 - Interrogatories to Parties, Tex. To make an objection to an interrogatory, in whole or in part, you must state the objection in writing within the time for responding to the interrogatory. 1-50. 3: Provide a summary of the expected testimony of each witness identified in response to Interrogatory No. ” (5) Discovery and Depositions § 19--Interrogatories to Other Parties--Objections and Scope of Inquiry--Prohibition of Compound, Conjunctive, or Disjunctive Questions. Interrogatories may relate to any matter, not privileged, relevant to the claims and defenses of any party. Form Interrogatory Nos. 2 through 5, 7 through 16, 18, 20, 22 and 23. Jan 12, 2010 · Instead of answering, may serve objections. ” Do you contend that plaintiff’s Objections to interrogatories must be stated with specificity, and the grounds for objection must be set out in the space following the interrogatory served or the restated interrogatory prepared by the responding party (D. Objections like this are meant to prevent testimony from becoming confusing. If the bases are unclear, the response is improper (see, e. • “Objection, compound” —If a question asks multiple questions at once, it is proper to object that the question is compound. Ambiguous. 010), by Mar 1, 2019 · Objections. Read why common individual objections are garbage and being used to thwart you. That means Nov 8, 2023 · Plaintiff responded to Special Interrogatories Nos. ” Given that backdrop, as to each interrogatory propounded, the first question you must ask yourself is, “Must I object?” The next thought you should have is,“Should I object?” followed by, “What objections are available?” Jan 1, 2023 · (f) No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question. 090] 2030. The objection may be made either in the response to the interrogatories or in a separate document. “First, the interrogatory asks plaintiff to state, with respect to each legal matter identified in response to Interrogatory 2, whether Matthews failed to perform satisfactorily, or made any omission in his performance of work. --In referring to the prohibition of compound, conjunctive, or disjunctive questions (Code Civ. Vague. But that doesn’t mean that you can’t prepare yourself to make objections when you have to. It lists 14 common objections including objections over relevance, scope, privilege, confidentiality, vagueness, unintelligibility, and requests for expert opinions or legal conclusions. The next key category of deposition objections is a lack of relevance. Although a discovery objection may be valid, it may not be valid in that case. Compound question Interrogatories are a frequently used discovery device, consisting of written questions propounded by one party to another. Its objections are that the question assumes a fact not in evidence, and that it is compound in form. Tex. com Your objection: “This interrogatory contains subparts and is compound, conjunctive, and/or disjunctive, in violation of Code of Civil Procedure section 2030. Civ. Typically, defendants will claim some sort of privilege and object. Subparts and Compound Questions. e. App. #200 Houston, TX 77024 Telephone: 713-255-4422 Fax: 713-255-4426 E-mail: info@silblawfirm. See full list on cpollardlaw. The interrogatory makes no such assumption, and it is not compound. No, not if the interrogatory is a Judicial Council Form Interrogatory. NRCP 33 (b)(4) (amended eff 3/1/19). This request calls for a legal conclusion and is therefore improper under the rules of discovery. How do lawyers handle compound questions in court? Lawyers handle compound questions by objecting to them if they believe they are confusing. After an objection is made and after the attorneys have had a chance to argue (if the judge allows it), the judge will rule on the objection. Landmark first argues that MLB waived its ability to object to interrogatories as compound. 710), and subject to the restrictions set forth in Chapter 5 (commencing with Section 2019. You may object if the request is asking for your analysis, strategy, or thinking about the case. For example, “Defendant objects to each and every interrogatory on the grounds that it is made, unlimited in time, invasive of attorney work product, seeks privileged information, ambiguous, blah, blah, blah…. , can’t have interrogatories in the same document) Sometimes, rather than admitting or denying the truthfulness of a fact, you may object to the request on legal grounds. Accordingly, Plaintiff cannot avoid answering the interrogatories based upon his compound objection. The question has been asked and answered. Thus, one question with two subparts could actually count as three interrogatories in both Level 1 and Level 2 cases. Jan 20, 2025 · Compound. or protected by the work product doctrine. Houston Office 950 Echo Lane, Ste. Generally, interrogatories are objectionable if they seek information not within the scope of discovery defined in Maryland Rule 402 or Federal Rule 26 (b). The judge will either sustain or overrule the objection. 060] Checklist of common objections *By: F. Jan 25, 2023 · Also the objections to special interrogatories numbers __ and __ also on the grounds of not being full and complete in and of itself, subparts, and a compound, conjunctive or disjunctive question does not state in detail how the particular interrogatory is compound, conjunctive or disjunctive, or how they contain a subpart. 040 - Declaration For Additional Special Interrogatories, Option of Seeking Protective Order Feb 18, 2025 · Service and Response Deadlines. Again, you need to head to your local rules and see how they handle compound questions. 27 The same kinds of objections are available in federal court as in state court, and attorneys may properly object to the form of questions that assume facts Raise this objection if the request requires you to do legal analysis and requests a legal opinion. V. 2030. But, do the Sep 23, 2009 · The objection to the term “economic damages” as vague and ambiguous was interposed to interrogatory Nos. Lacks foundation. Rule 33— Interrogatories to Parties (a) Availability. ” Objection: Relevance. The objections to interrogatory 11 were on the ground that it was compound and sought irrelevant and privileged matter. If you do not object to a request, those objections may be waived. Responses to requests for production and interrogatories are often littered with trite objections like “Objection: overbroad, irrelevant, privileged”—objections low on detail and high on obstruction. Unlike C. Argumentative. Such requests, which include the sometimes gray area of sorting fact from opinion, are objectionable. This way, you can provide clear and accurate answers to each part of the question. Under California Code of Civil Procedure 2030. (f)), the purpose is to FEDERAL RULES OF CIVIL PROCEDURE . ” It may be impossible to determine what the requesting party is asking. OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. Proc. , Ste. The propounding party may ask you to admit only one fact per statement. Calls for a legal conclusion. ” Even though several interrogatories may be objectionable on the same ground they may not be objected to as a group. Jul 13, 2016 · Definitions may be used in a set of interrogatories, and defined words must be capitalized whenever they reappear in the interrogatories. But, in addition to raising. W. 196. P. 2(a). Common objections to requests for admission include: The request is impermissibly compound. Substantive Objections 1. Civ. CCP § 2030. 1(b); Davis v. 2, 3, and 4 as follows: “Objection: The Interrogatory is overbroad as to time and subject matter, unduly burdensome, and impermissibly compound. Objection-Asked and answered •FRE 403, 611 •Objection. Aug 30, 2021 · Office Information. •Form of the Q does not have to be identical to raise this objection. 0 series, special interrogatory and production requests. 020 - Timing For Serving Interrogatories. 1. 210(a) (pdf) states that “[t]he party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory . 1(e)(2)(A), which provides that, when an objection is made to any interrogatory or subpart thereof or to any document request under Federal Rule of Civil Procedure 34, the - objection shall state with specificity all grounds. g. Dec 17, 2021 · Here’s a look at the dangers of compound questions and how to handle them. §§2030. Sep 27, 2021 · One type of request that frequently leads to an objection is one which seeks admission of a matter of opinion. Is my interrogatory compound, disjunctive or conjunctive? Should I just rephrase it as: "If you or anyone acting on your behalf contend that X had the authority to decide Y, on what basis do you contend that I had given him the authority to decide Y?" Defendant objects to this interrogatory on the grounds that it is premature, compound, and seeks the production of information that is subject to privilege, including attorney work product. Defendants responded to the interrogatories with the objection that the interrogatory is not relevant because the action is not a contract matter. 591 (1997) ("Learning to identify the proper objection in a split second is an intimidating task. Cal. ” The greatest problem arises with leading questions on cross-examination, when a single “yes” or “no” answer may be misleading because the witness intended his answer to apply to only one of the questions. It claims that MLB selectively withheld a response to Interrogatory No. C. Relevance – the evidence does not make any fact of consequence more or May 23, 2018 · Overbroad or “shotgun interrogatories. 2d 76 (Tex. Jul 30, 2010 · This may be a bit beyond the purview of an AVVO answer, but I would also tell you this: unless you have asked more than 35 special interrogatories without a declaration (see the Code of Civil Procedure on this topic) a compound question objection is not well based. 33's limit of no more than twenty-five interrogatories. Watkins, a landlord and a lessor. Jun 30, 2008 · Work Performed & Reasons Unsatisfactory = 2 Interrogatories. Definitions can help counsel avoid repetition in drafting interrogatories, but they should be tailored to the particular action. 33, even though it had not objected to either of the first two questions as being compound. 060, subdivision (f) provides: "(f) No specially prepared interrogatory shall contain subparts, or For More Information On the Web. R. Common objections include: The request is impermissibly compound. •Objection applies if W has given A, or W stated they don’t know A Oct 23, 2024 · Here are the discovery objections in California. and Federal law. An objection for compound requests or compound questions is appropriate when a discovery request combines multiple inquiries into one, which makes it difficult to determine exactly what’s being asked. 1 Interrogatories. Already answered or readily available. More likely than not, you will obtain objections to the 13. E. Calls for speculation. The Court does not agree that the Apr 21, 2009 · Responses to interrogatories are due within thirty (30) days if the interrogatories were personally served, thirty-five (35) days if the interrogatories were served by mail, and thirty (30) days plus two (2) court days if the interrogatories were served by express mail or facsimile or electronically. 3 (B)(3), the “discrete subpart” of an interrogatory is actually counted as a separate interrogatory. ” There’s no statutory provision for objecting on the ground that interrogatories are “too broad,” but courts use this objection to refer to interrogatories that request, e. Asked and Answered. 3 These might include quasi-disclaimers at the beginning of the document, such as, “objection to. on whether to make objections at all. 060, subd. Without leave of court or written stipulation, any party may serve upon any other party written interrogatories, not exceeding 25 in number including all discrete subparts, to be answered by the party served or, if the party served is a public or private corporation or a California Code of Civil Procedure - Interrogatories Table of Contents Propounding Interrogatories [CCP 2030. •Asked and answered questions are an attempt to emphasize the answer by repeating it. 010. Specific objections should be matched to specific Jul 2, 2021 · deciding how or whether to use the information in this chart. Absent compelling circumstances, failure to assert objections to an interrogatory within the time for answers constitutes a waiver and will preclude a party from asserting the objection in a response to a motion to compel. See D. This objection ensures the deposition stays focused on what’s relevant to the case, while helping to prevent questions that are unnecessary, potentially harmful, or time wasters. (a) Any party may obtain discovery within the scope delimited by Chapters 2 (commencing with Section 2017. Depositions and Discovery . The objection that the interrogatories violated section 2030. also need to recite the reasons. Irrelevant. This document provides a "cheat-sheet" of common objections that can be made in response to discovery requests. ” 8. CIV. The objection to interrogatory 10 was that it was compound. Blanket, unsupported objections that a discovery Plaintiff objects to the Interrogatories in their entirety to the extent any such instruction, definition, or Interrogatory purports to require Plaintiff to restore and/or search data sources that are not reasonably accessible on the grounds that such definitions and Interrogatories would subject Plaintiff to undue burden and expense. 193. Pate, 915 S. Vague or ambiguous. Code of Civil Procedure section 2030. 030 - Limitation on Number of Interrogatories That May Be Served. Sep 6, 2021 · A proper objection might include the following language: OBJECTION: This request is so vague and ambiguous in that there are no means to identify the information being requested. Question is leading when it suggests to the witness the answer or fact the examiner wants confirmed. For example, the California Code of Civil Procedure specifically prohibits compound, conjunctive, or disjunctive interrogatories. . Jan 28, 2025 · Relevance. We would like to show you a description here but the site won’t allow us. The scope of discovery is so broad that courts rarely sustain relevance objections. Irrelevant or not reasonably calculated to lead to admissible evidence. Seek an attorney’s help when navigating interrogatories, Instead, “form” objections refer to a category of objections, which includes objections to “leading questions, lack of foundation, assuming facts not in evidence, mischaracterization or misleading question, non-responsive answer, lack of personal knowledge, testimony by counsel, speculation, asked and answered, argumentative question, and Compound [Evid C §765] A question is objectionable as compound if it joins two or more questions, typically with “or” or “and. TEX. Objection. Code §765. A complete list of all evidentiary objections and related supports in D. Propounding Interrogatories CODE OF CIVIL PROCEDURE SECTION 2030. This objection can be used where a request uses a If you’re asked a compound question during a deposition, it’s best to ask the person to break it down into simpler parts. a litany of pre-drafted objections before answering the question posed. [CCP § 2030. Answers and objections are served together, so that a response to each interrogatory is encouraged, and any failure to respond is easily noted. Interrogatories must be relevant to the subject matter of the action OR appear reasonably calculated to lead to discovery of admissible evidence. TRIAL ADVOC. Jan 18, 2023 · 17: Objection; compound interrogatory;LURIA___CLABBY_FINAL SENT TO COPY 12/14/2005 5:12 PM 2005 An Expense out of Control 31 Put broadly, the problem with interrogatories is that lawyers believe, and the system reinforces, that the exchange and answer of interrogatories is a game ) If a party objects to production, the objection must indicate May 31, 2017 · With that in mind, the court announced that “from now on in cases before this Court, any discovery response that does not comply with Rule 34’s requirement to state objections with specificity (and to clearly indicate whether responsive material is being withheld on the basis of the objection) will be deemed a waiver of all objections Aug 16, 2021 · Below is Rule 197, which details the guidelines and procedures for making and responding to interrogatories: 197. As the responding party, you must either answer the interrogatory under oath or provide a specific objection. Code of Civil Procedure §§2030. Compound Request. This Guide will discuss special interrogatories; for information about form interrogatories, see If the opposing party has refused to respond to an interrogatory based on its objections, review the objections to ensure the bases for withholding a response are clear. All grounds for an objection must be stated with specificity. Ct. Work product. 801-03 regarding hearsay, its inadmissibility, and exceptions. The timing of contention interrogatories is governed by strict procedural rules. Warning: Interrogatories are particularly difficult and require a deep understanding of the law. This chart is intended as a * Responding Party objects that this Request is compound. You can also try this format: “If you contend that plaintiff’s conduct constitutes contributory negligence regarding the INCIDENT, state all facts on which you base that contention. This particular type of objection was critical in the case of White v. • If you are requesting an admission of the genuineness of documents, then they must be attached. Sep 27, 2023 · objection is overruled and defendants ordered to provide further responses. Introduction to Discovery – Part 6: Propounding Special Interrogatories Part 6 of this video series from the Sacramento County Public Law Library’s Civil Self Help Center will help you understand what special interrogatories are, and how to propound these types of requests. Oct 16, 2023 · What Are 10 Examples of Common Objections to Interrogatories? Overbroad or unduly burdensome. 2. 090 2030. May 1, 2024 · In summary, when faced with objections to compound questions or questions with sub-parts, the responding party should strive to provide substantive responses to each component of the interrogatory to the extent that it can be answered, unless the objection is based on relevancy and the information sought is not likely to lead to admissible • No subparts or “compound, conjunctive or disjunctive” requests. Objections is GRANTED to the extent that Defendant’s objection as to the alleged excessive number of interrogatories is OVERRULED and DENIED in all other respects. Here is a list of the objections that might be made if the facts warrant them. Nov 10, 2023 · Learn more about interrogatories, what to do if you are the responding party, what you can object to, and how much time you have to answer. You may use these objections as the complete answer to a set of interrogatories or in conjunction with your client’s answer. A specific objection to subsection (c) of interrogatory 10 was on the ground that the pictures, if any, would be the best evidence. D. Below is a comprehensive list of the categories of objections that can be used for each. The dangers presented by compound questions are mostly about potential confusion. FORM OBJECTIONS: Ambiguous and Unintelligible. Ritter, 2007 WL 2455873, *3 (S. party upon whom the interrogatories have been served shall serve a copy of the answers, and objections if any, within 30 days after the service of the interrogatories, except that a defendant may serve answers or objections within 40 days after service of the summons and complaint upon that defendant. The question has a double meaning, capable of being understood in more than one way. Small )May 31, 2018 As a practical matter, of course, most objections have to be made at high speed in the heat of battle, with little or no time for reflection. 010-2030. 260; CCP § 1013; CRC 2060(b)(2). ” This practice is widespread. Compound. , the identity of “all” persons or “every” person having knowledge of relevant facts. Evid. • There are two types of interrogatories: form interrogatories and special interrogatories. Super. 060(f). §2030. 10 Common objections in court 1. and Federal law is beyond the scope of this chart, which includes common objections and a sampling of related supports in D. Code §767 Dec 18, 2016 · Every lawyer who practices litigation knows the frustration of receiving general or “blanket” objections to written discovery. Interrogatory No. CCP §2030. The statutory authority for the “compound” objection is in Evidence Code section 765, which allows the trial judge wide discretion in controlling the examination of witnesses. 010 - General Information on Interrogatories. Sometimes, rather than answering the interrogatory, you may wish to object to the request on legal grounds. The party upon whom the interrogatories have been served shall serve a copy of the answers, and objections if any, within thirty (30) days after the service of the interrogatories, except that a defendant may serve answers or objections to interrogatories within forty-five (45) days after service of the summons and complaint upon that defendant. For instance, “admit you were there,” is vague and does not provide any specific information. A relevance objection is based on the argument that the evidence is not relevant to the case. See Willis v. 020, a party may serve interrogatories at any time after the lawsuit has commenced but must do so early enough to allow responses before the close of discovery, which typically occurs 30 days before trial unless modified by court order. — Corpus Christi 1996, no writ). 2 on grounds that Landmark had already exceeded the twenty-five interrogatory limit, see Fed. May 11, 2018 · The statutory authority for the “compound” objection is in Evid C §765, which allows the trial judge wide discretion in controlling the examination of witnesses. 50. As worded, the interrogatories contain multiple questions, compound questions, and subparts that necessitate more than 25 answers to interrogatories in violation of Rule 190. Defendant obj ect ed to the int errogator ies on the g round that they exceede d more than the synthesize some of the Common Objections in written discovery, in depositions and live testimony, and in a trial setting, and how to deal with the nuances that come along with objections. This interrogatory is overbroad and would allow undue access into the Respondent’s private information. 060(e). Generally, however, objections to interrogatories are asserted Mar 16, 2023 · Unless specifically discussed in reference to the interrogatory at issue, plaintiff has made no effort to justify the lengthy, general objections interposed with each of her responses and the court intends to overrule the objections. Plaintiff served 20 interrogatories on Defendant Aircom Management Corp. Waiver of Objections. wise. These are typically requests that are not relevant, unduly burdensome, broad, vague, or privileged. 0 series, I would advise serving special interrogatories and production requests seeking all sub rosa evidence obtained by the defense. R. P. . Feb 28, 2025 · Examples: “Objection. 210(a)(3)] Alternative to protective order TIP Don’t object to form (e. The law repudiates these objections, courts despise them, and litigants pay (literally and figuratively) for them. But even if both objections were meritorious, that would not be grounds for objection to an interrogatory propounded under the provisions of section 2030. 060(f)] Improper form [CCP § 2030. 1 and 6. Oct 7, 2009 · DISCUSSION B. Dennis Saylor IV and Daniel I. 060(f) states, “No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question. com Dallas Office 5050 Quorum Dr. Aug. Without waiving these objections, Plaintiff has devoted additional time making efforts to grow his existing business. Fed. Schoonover, by and through her undersigned counsel, files her Objections to the First Set of Interrogatories propounded by Special Counsel and says: 1. If an objection is not submitted in a timely fashion, that objection is waived unless excused by the court for good cause shown. 3 This is a Judicial Council approved interrogatory. Jan 16, 2015 · OBJECTIONS TO INTERROGATORIES The Respondent, Judge Linda D. Fleissner, Mastering Trial Objections: The Spin Control Method, 20 AM. The objections provided cover issues like prefaces in interrogatories, overbreadth Quick Reference for Common Objections & Responses . If an interrogatory is objectionable in part, the portion that is not objectionable must be answered in The article discusses Texas Rule of Civil Procedure 194 disclosure requests and their common issues, providing basic discovery without delays related to objections or work-product assertions. Relevance. 060(d). Unless he applies for a protective order, he is required to serve answers or objections in response to the interrogatories, subject to the sanctions provided in Rule 37(d). 2 (Level I)/190. Inc. Plaintiff’s response that “[she] 2010 California Code Code of Civil Procedure Article 1. Most jurisdictions set limits on the amount of interrogatories and admission requests a party can propound in one case. (g) An interrogatory may not be made a continuing one so as to impose on the party responding to it a duty to supplement an answer to it that was initially correct and complete with later acquired information. civil litigation. Hearsay – witness is asked to relate a statement other than a statement made by the declarant during present testimony. Leading. Objections to interrogatories must be stated with specificity. 04 of the Tennessee Rules of Civil Procedure provides as follows: (A) Objections to the competency of a witness or to the competency, Feb 4, 2025 · Filing objections to interrogatories must follow procedural rules to be effective. 010 - 2030. There’s actually no statute that specifically mentions compound questions. Mar 3, 2025 · The following types of objections in court are generally based on the rules of evidence most common in American jurisdictions. This template objections and responses to interrogatories is for your use in responding to interrogatories served by an adverse party in a Massachusetts state court civil case. Permitted on direct for hostile witnesses; always permitted on cross. 6 seek information regarding any contract or agreement alleged in the pleadings. interrogatory will invite an objection that the interrogatory isn’t “full and complete” under CCP §2030. 24, 2007) (party required to respond to compound interrogatories that sought relevant information). Compound questions can be used to circumvent these limits by asking more than one question in a single discovery request, making them objectionable. This is not limited an actual objection you may state, but situations in which you may be making the objection, may be Such objections do not comply with Local Rule 26. Calls for legal conclusions. Form Interrogatory No. Rule 32. Jun 26, 2017 · The defendant replied with an objection. "); see also James P. Oct 6, 2016 · Make sure the court does not have a preferred method or style for interrogatories. , Point of Law (POL), and you should seek the specific bases for the objections from the responding party. 700 In litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. A series of contentions For purposes of this article, “general objections” include prefatory-type objections that appear at the beginning of a document purporting to respond to discovery but fail to directly respond to any individual interrogatory or request. • Vague, Ambiguous, Unintelligible: A request can be “vague, ambiguous, or unintelligible. Rule 33 of the Federal Rules of Civil Procedure governs this process, requiring objections to be made within 30 days of receiving the interrogatories. 197 Objection. • If the Judge sustains your objection to testimony provided by a witness, the move to strike the statement. Interrogatories allow the parties to ask who, what, when, where and why questions, making them a good method for obtaining new information. qzm bpcgw kaa unqfxl blczny qyngnns wbz ludug zwwnxw ldzn uikwa yxnqq tqvzz bkbszb hooyite