Q: How to confront objection that interrogatory requests compilation or summary. How to obtain response?
Interrogatory indeed requires compilation or summary of information, critical to subject matter of the lawsuit.
How to obtain response?
A:
To address an objection that your interrogatory requests a compilation or summary of information, you should first ensure that your request is specific and clearly relevant to the case. Under California law, the responding party must provide information that is reasonably available to them. If the information you seek is critical to your lawsuit, emphasize its importance and relevance in your response to the objection.
You can argue that the burden of compiling or summarizing the information is outweighed by its necessity for resolving key issues in the case. Highlight any rules or precedents that support your position, such as the fact that the courts generally favor full and open discovery. Additionally, you can request that the court compel the other party to respond, demonstrating that you have made a reasonable effort to obtain the information through other means.
If the opposing party continues to resist, you may need to file a motion to compel discovery. In this motion, explain why the requested information is essential and how it impacts the fairness and completeness of the litigation process. Provide a clear explanation of how the lack of this information could prejudice your ability to present your case effectively.
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