Objections & Responses to Interrogatories: Practical Examples

One of this blog’s most popular posts is Objections to Interrogatories: A Guide for New Lawyers.  Continuing in that theme, below is an example of a good objection but also a poor response.

Bad Interrogatory:  “State with specificity all facts relating to YOUR communications with Plaintiff, Defendant Aero, Defendant Blood, Charles Wright, EMS Global One, Inc. and Federal Aviation Title Company LLC from January 1, 2011 to present related to matters alleged in the FAC.”[1]
Good Objection: Overly broad and vague.
Ruling: This “objection appears meritorious on the face of the record since the interrogatory as written would encompass such facts as the phone number used to call any of the above persons or entities, whether there was static on the phone line, and whether any such telephone call was patched through an assistant.”

Good Interrogatory:  Please state the material “facts relating to Defendant’s role and relationship with Aero II.”
Bad Response: Defendant “has no legal relationship or role with Aero.”
Ruling:  “Whether Defendant has a legal relationship is not the question posed, and the Court finds the answer provided to be evasive.”  A supplemental response was ordered.

[1] CC.Mexicano.US, LLC v. Aero II Aviation, Inc., No. 2:14-cv-00108, 2015 U.S. Dist. LEXIS 95500 (D. Nev. July 20, 2015).