If you’ve ever typed a really long set of discovery answers/objections, you’ve seen language like this:
“[Party] objects to this request on the grounds that it is vague, ambiguous, immaterial, irrelevant, not reasonably calculated to lead to the discovery of admissible evidence …”
In fact, every attorney I know has his/her own boilerplate discovery objections — full paragraphs containing every possible objection one can make to a discovery request.
You don’t want to type that over and over and over again for 37 different discovery requests, do you?
Good. I don’t want you to, either. So I’m going to show you how to get out of it. Without quitting your job.