Don’t waste the court’s time by objecting to discovery requests with boilerplate language. This case reaffirms the fact that courts want specific and tailored responses to discovery requests.
In this fraud lawsuit, the two parties could not come to terms on what would be produced by the defendants.
After a Rule 26(f) conference, the plaintiffs requested interrogatory responses and data from the defendants. The defendants refused to comply and objected to almost every discovery production request by the plaintiffs, stating that the plaintiffs’ requests were
“vague, overly broad, unduly burdensome… that is irrelevant and/or not reasonably calculated to lead to the discovery of admissible evidence.”
Hoping to resolve the dispute, the court held a conference. While it failed to resolve the discovery disagreement, it did unearth the fact that the defendants had not produced any data to plaintiffs. Subsequently, the plaintiffs requested the court order the defendant to comply with their requests.
Download the PDF version of RightChoice Managed Care v. Hospital Partners, Inc. case law alert here.
Litigators trained in the era of boilerplate discovery objections and maximum discovery resistance need to shift their approach to reasonable discovery cooperation. Otherwise they risk not only losing motions to compel but also being faced with additional burdens like, in this case, also having to detail their data preservation efforts.