I created this list to refer to when answering discovery. The idea was that the same objects are routinely used so instead of reinventing the wheel each time I could cut and paste each objection as needed. Many of them have the supporting law to go with them. The very last OBJECTION is used when the other side asks you to produce a document that is not currently in existence. I often use this in divorce cases when the opposing counsel uses the form requests for production that include a request for a current credit report. That document does not currently exist. I have argued the objection three times, winning twice and losing once.
Please see full List below for more information.
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