Methods For Asserting Objections Under Amended Rule 34

Law360, New York (March 2, 2016, 4:51 PM EST) -- What is wrong with this objection?

Defendant objects to this demand on the basis that it is overbroad, unclear, vague and ambiguous, improper in form, unduly burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence, requests information outside the defendant's knowledge and control and seeks information that is already in the custody and control of the plaintiff or is accessible to the plaintiff.

  Subject to the foregoing objections, the defendant produces the following documents…

This sort of boilerplate objection has been used by litigators for decades. But as of late 2015, this approach to responding...

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