Partner inserted an objection to a discovery request. OC sent a deficiency letter and now the partner is caving on the objection. Our response to the letter will be for my signature. How do I responded other than, "lol. You got us. That objection was BS"?

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Happens all the time. You just say that you have supplemented the responses where appropriate and lay out your position for objections you are maintaining. Then you invite them for a call.

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This

Just say we will produce and leave it at that

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Thanks!

all discovery is BS, except for depositions.

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Sad but true.

Alternatively, restate the objection, explain the grounds for it, and then say, “as a compromise, we will agree to produce ____.” But, as others have mentioned, the better approach is to just say “we will produce” and leave it at that.

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I like your response. “You got us.” Lol rule #1 of being a lawyer, never admit or take responsibility for anything when dealing with an OC. Instead just say something ambiguous and move on to what info you will agree to provide, notwithstanding your objections.

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You couldve left off everything after "never take responsibility for anything" and probably would've still been accurate from everything I've seen.

We will produce.

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“Dear X:

We are with drawing our [basis for the objection] objection to your client’s [362nd interrogatory] at this time. We are including a revised response to the [362nd interrogatory] with this letter.

Sincerely”

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