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LWms514

General Objection to Discovery as Untimely

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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?

 

EX: 

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)

EX: 

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.

OR

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

 

All suggestions are appreciated.

 

Thank you.

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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.

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