Written Discovery: How The Heck Do I Provide Detailed Objections When I Haven’t Collected The Data?

Panelists: Hon. James O’Hara, (U.S.D.C. D. Kan.); Philip H. Cohen, Greenberg Traurig, LLP; Matthew Moncur, Walmart

Description: F.R.C.P. 34 places great emphasis on objecting with specificity.  Couple that with the parties’ Rule 26(g) obligations and counsel on both sides are at risk of being sanctioned if their requests or responses are not narrowly tailored and specific.  Gone are the days of boilerplate objections or overboard requests for “any and all” documents.  With these constraints in mind, how should a party respond with specific and detailed objections during the early stages of litigation when data has yet to be collected, let alone reviewed?  How is a requesting party able to limit its requests when it has yet to see any of the data?  This panel will explore ways to overcome these obstacles in a manner that will satisfy the court. 

Written Discovery: How The Heck Do I Provide Detailed Objections When I Haven’t Collected The Data? was recorded on October 30, 2017.

MCLE Credit*: MO 1.1 self-study credit | KS 1.0 non-traditional credit

*Missouri limits self-study credit to a total of 6 hours per reporting period. Kansas limits non-traditional credit to a total of 6 hours per reporting period.

Registration Period: January 1, 2018 – December 31, 2018.

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