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Case shelved under Reasonableness

Specificity Required When Objecting to Discovery Requests

RightChoice Managed Care v. Hospital Partners, Inc.
W.D. Mo. February 1, 2019
Why This Case Is Important

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.

  • Judge Rules for Plaintiffs. The court found that the defendants (1) failed to comply with Rule 26(a)(1), disclosing custodian names with discoverable data, (2) must respond to plaintiffs’ requests and “tailor their objections with much greater particularity, and (3) disclose a “statement detailing their efforts to preserve discoverable information.”
  • Transparency around Custodians. The defendants only said “corporate representative[s]” held discoverable data. This action was in direct violation of Rule 26(a)(1), which instructs parties to disclose any specific custodians who are “likely to have discoverable information.”
  • No Boilerplate Language. As numerous other courts have ruled, they will no accept boilerplate language in objections or responses to discovery requests.
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Legal Analysis
On RightChoice Managed Care v. Hospital Partners, Inc.
David Cohen, Esq., Chair - E-Discovery Group, Reed Smith LLP
David Cohen, Esq., Chair - E-Discovery Group, Reed Smith LLP

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.

David Cohen's Bio
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