Jump to content

General Objection to Discovery as Untimely

Recommended Posts

OH rules state that if an objection is made, the reason for the objection should be made in lieu of an answer.  Should I give the cutoff dates and the date discovery was served by Plaintiff and received by Defendant?   I put the objection after each request and each interrogatory....is that correct?



Request for Admission number1:  Admit that your current balance owed is $1236.52/

Objection:  Plaintiff's First Discovery (inclusive of all requests for admissions, all interrogatories and all requests for productions) is untimely; therefore an answer is unnecessarily. 

OR (give more detail)


Objection:  Objection on the grounds that Plaintiff’s First Discovery (inclusive of all Requests for Admissions, all Interrogatories and all Requests for Production of Documents) is untimely:  Plaintiff’s First Discovery was submitted to Defendant after the Court’s Scheduling Order cut-off date; therefore, an answer is unnecessary.  Per the Court’s Scheduling Order, all discovery was to be submitted to opposing party or counsel by February  5, 2016 and answered by March 6, 2016:  Per the Certificate of Service included with Plaintiff’s First Discovery, the aforementioned discovery was served to Defendant on March4, 2016:  Defendant received Plaintiff’s First Discovery on  March, 9, 2016.


Objection:  Defendant, generally objects to Plaintiff's First Discovery as untimely.


All suggestions are appreciated.


Thank you.

Link to comment
Share on other sites

You're on target. In these instances, when one answer substantively responds to every request, I don't repeat it over and over. Just one, general objection, directed at all requests, is sufficient unless you are aware of specific instructions to the contrary.

Link to comment
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.

Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.


  • Create New...