July 20, 2015

In this article, Jenner & Block Partner Robert L. Byman examines lawyers’ tendencies to give “long-winded,” boilerplate objections to interrogatories.  Using an example from his own practice, Mr. Byman observes that “we do it because we always have.”  He then reviews a series of decisions in which courts have reaffirmed that general boilerplate objections are no objections at all.  He concludes by suggesting that lawyers should “discount the fact that everybody does it. Get over your fear that you may waive an objection if you don't raise every possible one. If you have a valid objection to an interrogatory, make it — tailored to the particular interrogatory. But don't make general objections.”