More often than not, written discovery responses elicit a variety of objections rather than substantive information responsive to the discovery request. The most common objections are asserted on the grounds of irrelevance, excessive scope and vagueness. Too often, the objecting party mistakenly believes that he or she is excused from providing a substantive response simply because an objection has been asserted.
This mistake, all too common in litigation, can bring dire consequences. A mastery of the discovery rules and the applicable case law can help you outmaneuver stonewalling tactics while protecting yourself and your client from the exorbitant costs of discovery battles, and potential as court-imposed sanctions. view more