Subject: Request for Review of Answer's and Objections to Plaintiff's 2nd Set of Interrogatories — Sample Letter Dear [Recipient's Name], I hope this letter finds you in good health. I am writing to bring your attention to the matter of the recently received response and objections to the Plaintiff's 2nd Set of Interrogatories in the ongoing case [Case Name] in Oakland, Michigan. As the legal representative for the Plaintiff, I hereby request your careful review of the provided answers and objections for further assessment. In order to facilitate a fair legal process and ensure proper discovery, it is essential that the answers and objections submitted by the Defendant be reviewed diligently. This review will enable us to assess the adequacy and accuracy of their responses and determine the need for additional actions, such as motions to compel, if necessary. The purpose of this letter is to formally request your expertise in scrutinizing the Defendant's responses and objections to each set of interrogatories. Your comprehensive assessment will assist in identifying potential issues, inconsistencies, or discrepancies that may need to be addressed and pursued during the litigation process. Outlined below, please find the key points to focus on during your review: 1. Thorough Analysis: Please conduct a meticulous analysis of the Defendant's answers and objections provided in connection with the Plaintiff's 2nd Set of Interrogatories. Scrutinize each response line-by-line, ensuring compliance with the court rules, accuracy, and completeness. 2. Legal Validity: Assess the objections raised by the Defendant for their valid basis within the rules of civil procedure. Identify any objections that are not well-founded or lack specific legal support, thereby giving rise to potential challenges. 3. Adequacy of Responses: Determine whether the provided answers sufficiently address the questions posed by the Plaintiff. Evaluate the clarity, relevance, and level of detail provided by the Defendant, comparing it to the nature and purpose of the interrogatories posed. 4. Evidentiary Support: Examine the responses for any lack of supporting documentation or evidence when requested. Evaluate whether the Defendant has provided appropriate documents or if further requests for production of documents may be necessary. 5. Compliance with the Court's Scheduling Order: Review whether the Defendant has abided by the designated timeframe for responding to the interrogatories, as mandated by the court's scheduling order. Identify any delays or non-compliance, assessing their potential impact on the case timeline. Once you have conducted a thorough review, I kindly request to schedule a meeting at your earliest convenience to discuss your findings. It is essential to strategize our next steps and determine the merits of any potential motion to compel or other necessary actions. Thank you for your continued dedication and support in navigating this case. I trust that your expertise and attention to detail will assist us in ensuring a fair and just legal process. I look forward to hearing from you soon. Sincerely, [Your Name] [Your Title/Position] [Law Firm/Organization Name] [Contact Information]
Oakland Michigan Sample Letter for Review of Answer's and Objections to Plaintiff's 2nd Set of Interrogatories
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FAQ
V. Sup Ct. (Rios) (1992) 7 CA4th 1384, 1391. Unduly burdensome requests are a misuse of the discovery process. Employing a discovery method in a manner or to an extent that causes unwarranted annoyance, embarrassment, or oppression or undue burden and expense is one of the examples of misuses of the discovery process.
Your answers to the interrogatories should usually be short, clear, and direct and should answer only the question that is being asked. This is not the time to set out your entire case or defense to the other side. Take the time to make sure your answers are correct and truthful.
Objections that may be used in the course of discovery include, but are not limited to the following: Unduly burdensome, Overly broad. Vague. Ambiguous. Disproportional. Protected by the attorney-client privilege. Work product doctrine.
Their use was usually the first volley in the discovery battle. For years the Courts had found that the Form Interrogatories were objection proof as to form with minor exceptions.
Contents hide 7.1 Irrelevant. 7.2 Privilege or Work Product Protection. 7.3 Overbroad. 7.4 Excessive Number. 7.5 Unduly Burdensome, Expensive, or Oppressive. 7.6 Vague and Ambiguous. 7.7 The Information is Already Known or Equally Available to the Requesting Party. 7.8 Speculation or Question Based on an Improper Assumption.
In a civil action, an interrogatory is a list of questions one party sends to another as part of the discovery process. The recipient must answer the questions under oath and according to the case's schedule.
Whether to admit interrogatory answers is within the discretion of the trial court, just as with any other evidence, and a trial court's refusal to admit such evidence will only be reversed upon a showing of manifest abuse of that discretion.
Make it a lead-off general objection. Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection. Use boilerplate wording from form files.
How to present a losing objection: Make it a lead-off general objection. Object to anything that is not relevant to the subject matter (no longer the standard) or not likely to lead to admissible evidence (no longer the standard). Don't say if anything is being withheld on the basis of the objection.
How To Write Interrogatories Local Rules. Step one: Read the local rules.Subparts and Compound Questions. Again, you need to head to your local rules and see how they handle compound questions.Tailored Definitions.Tailored Definitions Relating to Documents.Vague Interrogatories Beget Vague Responses.Detail Oriented.
