PLA1223 Rasmussen Week 2 Civil Litigation Response To Interrogatories

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PLA1223

Rasmussen University

Description

As a paralegal, part of your job will be to type up responses to discovery requests, including interrogatories. Sometimes, a client might have written out responses, and you will simply be typing them into the document. Other times, you will need to assist the client in formatting responses. Also, your supervising attorney may wish to "object" to certain questions. For this assignment, use the provided discovery requests from the defendant's counsel in this employment discrimination case.

Insert our client (the Plaintiff's), responses, which have been provided as well.

Do not change the content of the client's responses, but be sure to clean up the language for spelling and grammatical concerns. Your work will be reviewed by your supervising attorney before it is served, but he has advised you that he wants the following objections included in the responses:

  • Object to any question which requests medical information, as it is an invasion of privacy, not reasonably calculated to lead to the discovery of relevant information.
  • Object to any question requesting social media information, as the requests are overbroad and irrelevant.
  • Object to any questions that are unlimited in time (i.e., ask for all jobs ever held) as they are overbroad and unlimited in time.

It is your job to accurately format the objections. A set of general objections has already been placed in the beginning of the responses for you.

User generated content is uploaded by users for the purposes of learning and should be used following Studypool's honor code & terms of service.

Explanation & Answer

Attached.

Running head: RESPONSE TO INTERROGATORIES

Title: Response to Interrogatories
Student’s Name
Institutional Affiliation:

{5716437:}

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RESPONSE TO INTERROGATORIES

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IN THE UNITED STATES DISTRICT COURT
BLACKACRE
JOHNNY APPLESEED
Plaintiff,
v.
CRABTREE INC,
Defendant.

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CASE NO. 16cv5644

JUDGE JOE SMITH

PLAINTIFF’S RESPONSES TO DEFENDANT’S FIRST SET OF
INTERROGATORIES TO PLAINTIFF
Pursuant to Rules 26 and 33 of the Blackacre Rules of Civil Procedure, Plaintiff Johnny
Appleseed submits the following as his answers and objections to Defendant’s First Set of
Interrogatories.
GENERAL STATEMENT
A.

Plaintiff makes these discovery responses solely for the purpose of this action. Each

response is made subject to all objections to competence, materiality, relevance, or other
objection as to the admissibility that may apply in the event that any such response, or the
information contained therein, is sought to be used in Court. Plaintiff expressly reserves all such
objections.
B.

Plaintiff reserves the right to correct any inadvertent errors or omissions.

C.

Plaintiff makes no implied admissions regarding the contents of the responses below.

That the Plaintiff responded to a request, in whole or in part, should not be construed as an
admission that Plaintiff admits the existence of any facts, either stated or assumed by the request,
or that such response and/or objection, constitute evidence admissible against Plaintiff.

{5716437:}

Page 2

RESPONSE TO INTERROGATORIES

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GENERAL OBJECTIONS
A.

Plaintiff objects to the discovery requests to the extent they purport to impose obligations

and duties beyond those imposed by the Blackacre Rules of Civil Procedure.
B.

Plaintiff objects to the discovery requests to the extent they attempt to impose upon him a

duty to obtain and provide the Defendants with information not presently in their possession,
custody or control.
C.

Plaintiff objects to the discovery requests to the extent they call for the disclosure of

information or the production of documents protected by the attorney-client privilege, work
product doctrine or any other applicable privilege or protection.

In the event any such

information or documents are disclosed or produced inadvertently, such disclosure/production is
not intended as a waiver or any applicable privilege or protection and Plaintiff reserves the right
to seek the return of such inadvertently produced documents.
D.

Plaintiff objects to the discovery requests to the extent they seek information and

documents which are not relevant to the claims and defenses asserted in the pleadings, are not
reasonably calculated to lead to the discovery of relevant evidence and are otherwise not subject
to discovery under the Blackacre Rules of Civil Procedure.
E.

Plaintiff objects to the discovery requests to the extent they require the production of

electronically stored information because the requested production of such information is overly
broad, unreasonably burdensome and requires the expenditure of time and resources which are
prohibitively expensive and excessive based on the claims ...


Anonymous
Excellent! Definitely coming back for more study materials.

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