Defendant objects to this interrogatory as it calls for ...



DISCOVERY OBJECTIONS CHEAT-SHEET

Responding Party objects to this request as it calls for information that is not relevant, nor reasonably calculated to lead to the discovery of relevant or admissible evidence.

Responding Party objects to this request as it contains a preface in violation of C.C.P. § 2030.060(d) (interrogatories).

Responding Party objects to this request as it is not full and complete in and of itself as required by C.C.P. § 2030.060(d) (interrogatories).

Responding Party objects to this request as it calls for information that is confidential and privileged from disclosure pursuant to the attorney-client privilege and/or the attorney work product doctrine.

Responding Party objects to this request as it calls for proprietary, confidential, and/or trade secret information.

Responding Party objects to this request as it is overbroad in both time and scope.

Responding Party objects to this request as it is oppressive and unduly burdensome.

Responding Party objects to this request as it is vague and ambiguous as to the term “_______”/ in its entirety.

Responding Party objects to this request as it is unintelligible.

Responding Party objects to this request as it calls for an expert opinion.

Responding Party objects to this request as it calls for a legal conclusion.

Responding Party objects to this request as compound.

Responding Party objects to this request as the information requested is equally available to Plaintiff.

Responding Party objects to this request as Plaintiff already has any responsive information in its possession.

Responding Party objects to this request as assuming facts that have not been established.

This request seeks non-admissible evidence of subsequent remedial measures and therefore is not reasonably calculated to lead to the discovery of admissible evidence.

Responding Party objects to this request as it improperly seeks information protected by personal rights to privacy.

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