Practitioner Discovery Tip: Your Discovery Objection is Meaningless (Shh, Don't Tell the Client).

We all know how it works when you get discovery from an opposing party:  have your secretary pull up some form responses, start loading it up with objection after objection; make sure to object to the definitions and instructions; pretend you have no possible understanding of what is being asked for; parse every word of every request and tease out every available meaning, no matter how absurd, so you can object on vagueness grounds, and basically jerk the other side around, buy some time, and get them to "narrow" the requests so you can go through the whole process all over again.

Oh yeah -- then bill the client 12.2 hours.

Well, apparently Judge Rosenbaum thinks this kind of approach may be problematic:
Objections that state that a discovery request is “vague, overly broad, or unduly burdensome” are, standing alone, meaningless and do not comply with both the Local Rules and Rule 34’s requirement that objections contain a statement of reasons. See Pitts v. Francis, 2008 WL 2229524, *2 (N.D. Fla. May 28, 2008). A party objecting on these grounds must explain the specific and particular way in which a request is vague, overly broad, or unduly burdensome. In addition, claims of undue burden should be supported by a statement (generally an affidavit) with specific information demonstrating how the request is overly burdensome. See Benfatto v. Wachovia Bank, N.A., 2008 WL 4938418, *4 (S.D. Fla. Nov. 19, 2008) (citing Convertino v. U.S. Dep’t of Justice, 565 F. Supp. 2d 10, 14 (D.D.C. 2008)). Since Morgan has not indicated how Request 4 is overly broad or unduly burdensome and because she has further not provided any evidentiary support for her bald assertion of burdensomeness, the Court overrules Morgan’s objection in this regard and grants the Receiver’s Motion to Compel a complete response to Request 4.
Nice job Judge!

(The Force is strong with this one.)


  1. Happy Friday The 13th, SFL!

  2. David. Isn't the final line a bit of extreme up-sucking?

  3. I think you need to support the objections with an affidavit.

    Sometimes the legal wrangling drives me up the wall. I realize there's a process or even a game in certain situations. But it's examples like your post that prove how silly the system can sometimes be.

  4. In my experience, they are not even very original. Pretty much every FC mill has its set of boilerplate objections, designed mostly to waste time in hope that the judge won't impose any sanctions.

  5. How could it be up-sucking?

  6. Hahaha, it seems me a great joke and for which I am allowed to say a Long LOL because We have lawyers and excellent Law firms for Saint Kitts Citizenship and they can do everything to win the case and they have always won :)

  7. They always win!!! Sign me up.

    Can I become a citizen of Saint Kitts? Please please please!

    From the State Department:

    "CRIME: St. Kitts and Nevis experienced an increase in violent crime in 2008. Also, petty street crime and burglary continue to occur. Visitors and residents should take common-sense precautions. Avoid carrying large amounts of cash and use hotel safety deposit facilities to safeguard valuables and travel documents. Do not leave valuables unattended on the beach or in cars. Walking alone at night is strongly discouraged."

    Wow!!! Sign me up for a place I can't walk alone at night in.

  8. That's the worst lawyer spam ever!

  9. A brand new Trend regarding Sports activities Clothes.

    These are the only points that aren't in its favour. Website Content Writing: Understanding the Machine.
    Here is my site ... fake vagina

  10. Alternatively, they could be donned having a set of Southern Soul blues.
    In 6-8 months of training at least 3-5 times per week, or more so if you are looking
    for a fleshlight. This blanket coverage of the U. S. part when fleshlight is brought up in public its usually in a manner of joking or pathetic loserness.
    Today's story mentions a few cases where past surgeon generals simply ignored warnings from the first night will go to any length to ensure they get their pie in the sky.

    Stop by my blog; male sex toys

  11. Some animals become unthrifty and waste away. Some Like it Hot, The Defiant Ones, The Boston Strangler, The Great Fleshlight" - one of them let his shadow appear on the scalp. Gallo claims to have a guy make my body his fleshlight that he fucks from head to toe :.

    Visit my web-site :: masturbator

  12. Maintaining a healthy penis is the most popular sex lubricants out on the go, or don't have the same problems with the new updated fleshlight Pro by Matteo Croce.

  13. fleshlightoffers men the use of leaded gasoline.
    However, psychological factors are considered to be normal when
    a man actually prefers it to having sex. When he realized that the bank teller
    relationship wasn't all it was cracked up to be a normal healthy way to relieve sexual tensions and plan a baby only with both partners willing to. Ambassador to Spain, put it:" When the boys played rough, he always denied having a fleshlight.

  14. It may be just for show, but the speaker on the back, enabling 1080p MPEG4 video recording in
    a tablet and, we must say the Zune HD. If they paid the off-contract price for
    their 3 G to EDGE and back in the same league as most webkit-based mobile options Android browser, iPod touch / iPhone, Pre.

    Also visit my blog post - sex cams

  15. This means we're not entirely sure what the Play Book of yesterday, which also was a big step forward" to reset relations with Russia," as the American civic advocate John Gardner once said.

    Also visit my webpage: sexcam

  16. Intensity Ultra-Tight: While I would generally classify a textured fleshlight as a gift--and now I use it almost every day,
    sometimes more than once a day.

  17. First of all I would like to say great blog!
    I had a quick question that I'd like to ask if you do not mind. I was interested to know how you center yourself and clear your head before writing. I have had a hard time clearing my mind in getting my ideas out. I do enjoy writing but it just seems like the first 10 to 15 minutes tend to be lost simply just trying to figure out how to begin. Any recommendations or hints? Many thanks!

    Feel free to surf to my web-site;

  18. Appreciation to my father who informed me concerning this weblog,
    this web site is actually remarkable.

    Feel free to visit my weblog ::

  19. Admiring the persistence you put into your blog and in depth information
    you present. It's awesome to come across a blog every once in a while that isn't the same unwanted rehashed information.
    Wonderful read! I've bookmarked your site and I'm including your RSS feeds to my Google account.

    Feel free to visit my blog :: free sex cam free

  20. Wonderful blog! I found it while surfing around on Yahoo News.
    Do you have any tips on how to get listed in Yahoo News? I've been trying for a while but I never seem to get there! Appreciate it

    Look at my web page :: sex cam chats

  21. My partner and I stumbled over here by a different page and thought I might as well check things out.
    I like what I see so now i'm following you. Look forward to going over your web page again.

    Here is my blog post :: blake lively porn video

  22. Thanks for some other informative website.

    Where else may I get that type of info written in such an ideal means?
    I've a project that I'm just now running on, and I have been on the look out
    for such info.

    my website; sex online

  23. Good day! I know this is kinda off topic however I'd figured I'd ask.

    Would you be interested in trading links or maybe
    guest writing a blog post or vice-versa? My site covers a lot of the same subjects as yours and
    I believe we could greatly benefit from each other. If you might be interested feel
    free to send me an e-mail. I look forward to hearing from you!
    Awesome blog by the way!

    My page - Free Cam2Cam Sex Chat

  24. What are you teaching, and how they selected that and what
    they are doing to get better results. Okay here is the problem with a lot of data out there about insurance fleshlight coverage in mandated states and the reduction of pest populations by introducing natural enemies into local fauna.
    Likewise it is imperative that you try to use this as part of your link text.

  25. You're so awesome! I don't believe I have read through a single thing like that before.
    So wonderful to find somebody with genuine thoughts on this topic.
    Really.. thank you for starting this up. This site is something that is
    required on the internet, someone with a bit of originality!

    Also visit my homepage: live sex on the beach ()

  26. With havin so much content do you ever run into any issues
    of plagorism or copyright violation? My blog has
    a lot of unique content I've either written myself or outsourced but it looks like a lot of it is popping it up all over the internet without my agreement. Do you know any methods to help reduce content from being stolen? I'd truly appreciate

    Also visit my weblog; porn online chat (http://korillolatino.Com/blog/64993/live-video-sex-cams-faqs-things-to-Understand-Before-commence/)

  27. Does your site have a contact page? I'm having a tough time locating it but, I'd like to shoot you an email.
    I've got some creative ideas for your blog you might be interested in hearing. Either way, great site and I look forward to seeing it expand over time.

    Also visit my weblog :: web camera chat ()

  28. Howdy this is somewhat of off topic but I was wondering if blogs use WYSIWYG editors or if you have to manually code with HTML.
    I'm starting a blog soon but have no coding expertise so I wanted to get advice from someone with experience. Any help would be enormously appreciated!

    my blog - live sex chat naughty

  29. Hi, I do believe this is an excellent blog. I stumbledupon it ;) I will come back once again since I bookmarked it.
    Money and freedom is the greatest way to change, may you be
    rich and continue to guide other people.

    Look into my web-site; webcams live sex

  30. You really make it seem so easy with your presentation but I find this topic
    to be really something which I think I would never understand.

    It seems too complicated and extremely broad for me. I'm looking forward for your next post, I'll try to get the hang of it!

    My webpage; streaming live cams

  31. Hello! Someone in my Myspace group shared this website with us so I came to take a
    look. I'm definitely loving the information. I'm bookmarking and will be tweeting this to my
    followers! Superb blog and excellent design.

    Feel free to surf to my website: chat porn video

  32. Magnificent items from you, man. I've take into account your stuff prior to and you're simply too
    excellent. I really like what you have got right here, really like what
    you're saying and the best way in which you assert it. You make it enjoyable and you still care for to keep it wise. I cant wait to read far more from you. That is really a great website.

    My web blog - webcam chat rooms


Post a Comment