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Discovery Objection Procedures

Butler Snow LLP

Changes Coming in 2020 to Rules Governing Interrogatories? Proposed Rule 33.01 Amendments Aim to Provide Guidance

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Interrogatories can serve as a useful tool for parties to obtain basic information about their adversary’s case and drive discovery strategy. Serving interrogatories allows parties to identify individuals with knowledge and...more

Jones Day

Texas Appellate Court Rules on Discoverability of Settlement Agreements

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In In re GreCon, Inc., a Texas appellate court recently addressed when a party must produce settlement agreements. The plaintiff sued multiple defendants in tort after a fire, and settled with all except GreCon. After...more

Troutman Pepper

Practice Pointers to Best Utilize or Respond to Document Requests: Sedona Publishes Rule 34 Primer

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The rules governing how litigants conduct written discovery changed substantially on December 1, 2015, when major amendments to the Federal Rules of Civil Procedure took effect....more

Jones Day

Eastern District of Texas Latest Court to Criticize "Subject To" Language in Discovery Objections

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The Eastern District of Texas recently criticized a party's statement in its written discovery responses that it would produce documents "subject to" its objections. See Realpage, Inc. v. Enterprise Risk Control, LLC, No....more

Carlton Fields

Be Punctilious, Or You Might Inadvertently Waive A Personal Jurisdiction Objection In Federal Court

Carlton Fields on

May you preserve an objection to personal jurisdiction by including a general denial to the complaint’s allegation in your answer and then moving to dismiss on personal jurisdiction grounds less than three (3) months later?...more

Polsinelli

Respond with Caution! Responses to Discovery "Subject to the Stated Objections" May Waive Your Client's Objections

Polsinelli on

A growing number of federal courts have confirmed that the once-common discovery practice of asserting an objection followed by a bare "conditional" response, i.e., stating that "Subject to and without waiving the stated...more

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