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If you don't put your objections you wave them if you want to later raise them.
As you already mentioned, sometimes there really is something you don’t want to answer, or don’t want OC to know, so object if you can before answering it.
Sometimes you just want to avoid making your client do a buttload of unnecessary homework.
Sounds like you are asking about a situation where you don’t have a problem answering but you have the ability to object. I would say best practice, generally speaking, is to object whenever you can to make things difficult for OC. Depends on the case and client goals/budget though.
Do you try cases????
Objections are preserved for trials
In my experience it’s important to preserve objections. Let’s say for example someone asks you to produce all documents related to the dispute. You can’t determine which documents the proponent thinks are “related”, so you object but provide the documents YOU think are related. By objecting, you throw the burden back onto the proponent and forestall potential argument you withheld “related” documents.
Exactly!
I couldn’t imagine not using objections as a completely valid means of limiting, framing or couching the response. When you are representing large entities you need to use objections to set the boundaries of the response and the search for responsive information otherwise a response would be incomplete or you would incur literally millions of dollars in both client and outside counsel time searching for and describing the responsive information that is not even relevant to the dispute.
I object to this post on the basis that it contains too much common sense is beyond the scope most lawyer’s comprehension. I further object on the basis of privilege and confidentiality- stop giving away insider bill padding secrets! Without waiving these objections or the general objections, I answer as follows: objections make us sound tough and smart, which justifies our high priced bills and makes our clients think we are highly educated. Further answering, we are all terrified of making a mistake, so we need to CYA everything.
I’d bill a 0.4 for this reply alone.
In my experience, it’s best to throw all of your applicable objections into the responses just to preserve them on the record. If you don’t include the objections, you waive them. If the opposing party files a motion to compel, your objections will help prevent the disclosure of documents/information that you may have been saving for a later disclosure.
During my training, the training presentation discussed this same issue and gave an example of how a “former coworker” failed to preserve expert witness objections in interrogatories, RFAs, & RFPs. Opposing counsel filed a motion to compel and coworker was forced to disclose expert witness information.
Because OC is usually fishing with dynamite. Check that, a nuke.
It’s way out of control. Real objections are fine buy throwing everything in just to cover the bases is obnoxious. I wish Judges would stop tolerating the practice
Coach
I wish lawyers (and the ridiculous clients) would stop needing judicial intervention to engage in discovery. In my mind, if it’s relevant, produce. If it’s damaging, keep it the fuck out of the jury, but you cannot fail to produce it. It. Will. Come. Out.
Because they’re waived if we don’t raise them. Because most opposing counsel seem to be on a fishing expedition for documents that are completely irrelevant to the case. Because there aren’t many methods available to the defense to limit responses to overbroad requests. Because the courts have taken an extremely broad view of allowable discovery in this state, and I have to object now to have any hope of keeping it out of trial later.
Sometimes, I answer part of the question with things I don’t find objectionable to keep things moving, but preserve the objection so that they don’t claim we failed to adequately respond. For example if they tell me to provide every document that ever existed in the company related to issue X, I may think that’s overbroad and not proportional to the needs of the case, so I will object and say that it’s overbroad and unduly burdensome, but I will still provide what I think is reasonable, despite the objection. By preserving the objection, no one can later say that I left something out of discovery that I was supposed to provide. 
The only time they’ve really been helpful is when the interrogatory is slightly or completely ambiguous and even if I know the answer OC is looking for or the question they want to ask, it forces them to clarify and specify their request so my response can be as detailed and pointed as possible rather than having to write “assuming Defendant meant to ask this question, here is our answer.”
A6 do you mean to say we, as lawyers, would ever dream of playing with words and don’t always give the open honest complete unedited full truth?!?!?! I’m *appalled*!!!!!
Stop sending overly broad rogs and I won’t have to object and answer at the same time. Plaintiff’s attorneys could have a car accident case and their request be like “List any and all cars you’ve ever been in since your mom was pregnant with you, providing the name of the car, the color, license plate, and date, time, and location of your occupation of the car.” Lol yea I know you’re trying to ask if my client was in the car at the accident but the way you ask it forces me to dump 73748283 objections before saying “yes, my client was in the red Toyota at the time of the accident.” Otherwise I risk that you try playing games by later saying I have to provide more info cause I didn’t object.