Proc. ), To a certain extent, it appears that the trial court misapprehended the stage of a proceeding at which a privilege log becomes relevant. Wisconsin courts should also take guidance from the Federal Rules of Civil Procedure Advisory Committee Note, 2015 Amendment, which indicates that Rule 34 was amended to eliminate: the confusion that frequently arises when a producing party states several objections and still produces information, leaving the requesting party uncertain whether any relevant and responsive information has been withheld on the basis of the objections.4, Nor should courts accept reasoning that boilerplate objections are listed to preserve the objections, for the federal courts have produced a litany of decisions finding that boilerplate objections are improper unless based on particularized facts.5. Imlisted in Super Lawyers and Best Lawyers in America. Failure to Specify May Result in Waiver [] any objection on the grounds of attorney-client or work-product privilege is by the board here as a result of no privilege log verified., The court's minute order for the November 3, hearing reads: Defendant's objections are overruled. C 14-3041-MWB - Document 136 (N.D. Iowa 2017), U..S. District Judge Mark W. Bennett expressed his frustration with the continuing practice of general and boilerplate objections, saying, "This case squarely presents the issue of why excellent, thoughtful, highly professional, and exceptionally civil and courteous lawyers are addicted to . Two highly respected and influential federal judges are leading the charge: SDNY Magistrate Judge Andrew Peck and N.D. Iowa Judge Mark Bennett. Written discovery is an invaluable tool used in litigation. This writ proceeding involves a discovery dispute in commercial litigation between plaintiff Granatelli Motorsports, Inc. and defendant Best Products, Inc. This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. 116 0 obj <> endobj Both rules give the respective state or federal court the power to sanction attorneys whose discovery objections violate Rule 26(g) and section 802.05. 5. Two of those citations were borrowed from the excellent Matthew Jarvey, Boilerplate Discovery Objections, 61 Drake L. Rev. Earn one hour of GeneralMCLE credit by reading the article below and answering the questions on theSelf-Study MCLE test. We issued a temporary stay order and requested and received preliminary opposition from plaintiff. Not sure what you mean by boilerplate objections in this instance. Fisher v. Network Software Assocs., 217 F.R.D. She contends Defendants boilerplate objections are invalid. 466, 491 (N.D. Tex. %PDF-1.5 % Litigators should recognize that the rules of civil procedure under both federal and Wisconsin law do not authorize the use of form boilerplate objections. Failing to specifically inform the requesting party of the basis for an objection creates uncertainty because the requesting party cannot determine whether a discovery response is complete or whether discoverable information is being withheld unjustifiably. The party asserting privilege, in this case [defendant], has the burden, when challenged, of showing that the evidence it seeks to suppress is within the terms of the statute establishing the privilege, i.e., a communication between a client and a lawyer. Parties shall not make nonspecific boilerplate objections. The days of filling the first 10 pages of a written discovery responses with boilerplate objectionsare coming to an end. That application is not included in the present record. Failing to respond or to submit to an authorized method of discovery. If appropriate, challenge the expert's qualifications. Such objections do not comply with Local Rule 26.1(e)(2)(A), which provides that, when an objection is made to any interrogatory or subpart thereof or to any document request under Federal Rule of Civil Procedure 34, the - objection shall state with specificity all grounds. Do not submit blanket or boilerplate objections to the opponent's statements of undisputed fact. All attorneys are familiar with the routine form boilerplate objections: relevance, overbroad, oppressive, burdensome, harassing, vague, ambiguous, attorney client-privilege, and attorney-work product, etc. CA. at 191 (stating that [j]udges need to push back and do their part to solve this cultural discovery boilerplate plague because issuing sanctions for each violation would have a dramatic effect on the unauthorized use of boilerplate objections). General objections, also known as boilerplate objections, may be of some value. There are many other objections that may be raised in your responses to requests for admission. Stay up-to-date with how the law affects your life. 3 Big Trends Facing Legal Departments in 2023. The California Code of Civil Procedure clearly states that a motion to compel lies when objections are too general. Okla. Feb. 24, 1989). 2 See Heller v. City of Dallas, 303 F.R.D. The use of such form objections is an evasive and obstructive discovery practice that undermines the purpose of civil procedural rules that otherwise serve to promote the free exchange of discoverable information among parties. If your client fails to provide timely responses, the propounding party may move to compel your clients responses and seek monetary sanctions against you and your client.5 By failing to provide timely responses, you expose yourself and your client to sanctions and your client waives any objections, including those based on any privilege or attorney work product.6, If your client provides evasive, incomplete or insufficient responses, fails to produce all non-privileged responsive documents or objects without merit, the propounding party may also move to compel and seek sanctions against you and your client.7, The court must impose monetary sanctions against any party, person or attorney who unsuccessfully makes or opposes a motion to compel further discovery responses unless the court finds substantial justification or that imposition of sanctions is unjust.8, The court may also impose non-monetary sanctions for abuse of the discovery process. Its long been established that boilerplate objections to discovery requests will not be allowed, but in this case Doma Title Insurance v. Avance Title, LLCthe court permitted the defendants to supplement their objections rather than considering them waived. . The trial court can make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Section 2023. [Citation.] Id. (a)(3).) Defendant responded with, inter alia, boilerplate objections of attorney-client privilege and work product privilege. Boilerplate objections are routinely denounced by federal courts. To make the problem even worse, these general objections are typically incorporated by reference into each subsequent answer or response, unnecessarily obstructing the discovery process. Be selective with your objections. Once again, these sensible federal requirements should be readily endorsed by state court judges who have broad statutory authority to control discovery methods.3. The statute authorizes the court to make orders compelling further responses that adequately identify and describe documents for which a party (here, defendant) has raised boilerplate assertions of the attorney-client and work product privileges. This sample collection of meet and confer letters for discovery in California contains over 10 sample meet and confer letters and responses to meet and confer letters including a (1) meet and confer letter for further discovery responses to interrogatories, requests for admission and requests for production of documents, (2) response to meet and Andrew J. Peck (ret. The above is an example of inappropriate boilerplate objections. There is absolutely no requirement that a privilege log be tendered at this point of the discovery proceedings. Maybe they send a lengthy response, all paid for by the insurance company, in which they repeat the boilerplate objections. General Objections are meaningless, and they purposely obscure substantive written discovery responses. You have the burden to support the privilege objection with admissible evidence. Send your answers, along with a check ($30 per credit hour for CCCBA members / $45 per credit hour for non-members), to the address on the test form. This blog has frequently been listed by the ABA Journal as one of the top blogs in the country, and has been cited in dozens of law reviews. In Sandoval, a man on probation swallowed a lethal amount of meth rather than let deputy sheriffs find it, and died while in . Code of Civil Procedure section 2030.290 provides that if responses to interrogatories are not timely, all objec tions are waived, including the work product protection. No judge wants to see objections to every paragraph of a declaration or a page after page of boilerplate objections. hW[S:?3t-=a[(\Ri9G$. Even if your clients position on the substantive discovery issues prevails, you may still be subject to sanctions if the court finds that you failed to adequately confer with opposing counsel to avoid a discovery motion. Part of this success owes to the Day Forward program implemented years ago, which years ago began pooling together all the cases of a given year together for management by a single judge, particularly when it comes to discovery disputes. Rule 2-402(f) governs the production of statements given by parties or witnesses, not the scope of expert discovery. Let a peremptory writ of mandate issue compelling respondent court to set aside its order of November 3, 2003, overruling defendant's objections of attorney-client privilege and work product privilege to the discovery propounded by plaintiff on July 30, 2003, and to make a new and different order directing defendant (1) to serve further responses to the production requests which include a particularized identification of all documents to which the attorney-client or work product privilege is asserted and the facts justifying assertion of the privileges, and (2) to serve further responses, without objection, to interrogatories requesting identification of relevant documents but not their contents. CV DSF ORDER RE MOTIONS FOR SUMMARY JUDGMENT When filing or opposing a motion for summary judgment, a party is to . Subdivision (g)(3) requires a responding party who objects to the demand for inspection of a document based upon a claim of privilege, to (A) identify with particularity [the] document , and (B) set forth clearly the extent of, and the specific ground for, the objection , the particular privilege [and][i]f an objection is based on a claim that the information sought is protected work product under Section 2018, that claim shall be expressly asserted. (Hernandez v. Superior Court, supra, 112 Cal.App.4th at p. 292, fn. California has very liberal discovery attitude that prefers that all parties have what they are looking for in discovery unless the action is so egregious. "general objections" at the beginning of the response and then incorporating the objections into each response "to the extent they apply." Second, by interposing a litany of boilerplate objections to each discovery request and then answering the request "subject to and without waiving" the objections. Imlisted in Super Lawyers and Best Lawyers in America. An objection to part of a request must specify the part and permit inspection of the rest. When must/should an objection be stated? The operative pleadings are the complaint and cross-complaint. Each response . C. The parties met and conferred about the Document Requests at an inperson meeting on October 29, 2010. Bi-Weekly Newsletter of the State Bar of Wisconsin. Links to . Id. This statutory framework rebuts plaintiff's argument that defendant is claiming it can banketly [sic] assert the attorney-client privilege to requests for production of documents and interrogatories (which seek the identity of documents), and then refuse to substantiate such claims in any manner, or form, prior to a hearing on a motion to compel and then maintain that counsel and the Court should just take its word that the privilege somehow applies.. endstream endobj startxref [Citations.] ), Senior Counsel, DLA Piper. 6. Fla. 2011) ([J]udges in this district typically condemn boilerplate objections as legally inadequate or meaningless.); accord Ritacca v. Abbott Laboratories, 203 F.R.D. For these reasons, Wisconsin state courts should align with the federal courts and not countenance the ongoing use of boilerplate objections. Those two methods are: (1) the disclosure of a privileged communication in a nonconfidential context and (2) the failure to claim in the privilege in a proceeding which the holder has the legal standing and opportunity to do so. Persisting, over objection and without substantial justification, in an attempt to obtain information or materials that are outside the scope of permissible discovery. California 900 49 T: 310.651.8685 F: 310.651.8681 SELARZ LAW CORP. DANIEL E. SELARZ (State Bar No. 4 Rule 34, Fed. Several motions ended up resolved by agreement when the judge made the parties talk things out. Further, boilerplate objections lack sufficient information to allow courts to properly evaluate the merits of the objection being asserted, and as a result, cause delay, expense, and congestion in the administration of civil cases.1. Copyright 2023, Thomson Reuters. It is all typically connected to the same interests trying to limit civil discovery (as too expensive) and to deny access to civil justice, which comes as no surprise. ] It also urged defendant's responses, including its assertions of the attorney-client and work product privileges were raised in a repetitive, meaningless boilerplate fashion [with] no attempt to link the specific objection to the specific documents [defendant] purports are privileged or otherwise not discoverable. Plaintiff conceded the categories of documents it sought may encompass documents that are subject to a privilege [but that if defendant intended to raise that privilege, it] must prepare a privilege log setting forth sufficient information to determine whether or not any privilege applies [Defendant] fails to do so. Plaintiff served a set of requests for inspection and production of documents and propounded a set of interrogatories. Objections to the form of the question include: argumentative; 7. asked and answered; 8. assumes facts not in evidence; 9. Sacramento, CA 95814 (916) 874-6012 DISCOVERY Responding to Requests for Admission This Guide includes instructions and sample forms. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. 6 See Liguria Foods, 320 F.R.D. Reviews & Testimonials; . 37. The defense lawyers either dont answer at all, or they serve boilerplate objections. Thus, counsel should respond to meet and confer letters promptly and address, in good faith, all issues raised by the propounding party. Certificates are dated as the day the form is received. All rights reserved. The expression is jargon, commonly used by courts and attorneys to express the requirements of subdivision (g)(3) of section 2031. BEST PRODUCTS, INC., Petitioner, v. The SUPERIOR COURT of Los Angeles County, Respondent; Granatelli Motorsports, Inc., Real Party in Interest. Dahl v. You should, therefore, always seek to counsel your client to provide responses in good faith and as best as the client can.13 Discovery responses must reveal all information then available to the party and cannot plead ignorance to information which can be obtained from sources under [the partys] control.14 Like witnesses, parties are required to state the truth, the whole truth, and nothing but the truth in answering written interrogatories and a party may not provide deftly worded conclusionary answers designed to evade a series of explicit questions.15 On the flip side, strongly consider your grounds before filing a motion to compel. Get the e-discovery, legal news, and content youre looking for. 18-55289, holding that perfunctory evidentiary objections are disallowed, and summarizing other objections that simply don't apply on summary judgment.. But in the larger damage cases I have seen the good faith (some courts call it amicable resolution, others a meet-and-confer) requirements abused with alarming and increasing frequency. 4. hb```f``9`"/urPpu8i`~-H4/|1j8J70MK P9leihz#XZY( v S@(K7&%@32VJC])KXIf e`28 Jan. 13, 2021) No. boilerplate. Responding party objects to this request as it seeks documents that are not within defendants possession, custody, or control. I co-founded my own law firm, Kennerly Loutey LLC. 5. 3. [Consequently,] a privilege log is unnecessary with regard to answering interrogatories seeking the identification of documents. 4. New York now requires the responding party to affirmatively state that the document production is being made as requested, or state "with reasonable particularity . [Citations. Before your next summary-judgment motion, be sure to read Sandoval v.County of San Diego (9th Cir. Conducting written discovery is a crucial part of litigation. Statutory law recognizes only three methods by which a party can waive a privilege. The responsibility of litigants to comport with these certification requirements also warrants an examination of what the discovery rules specifically authorize regarding the use of objections: Interrogatories under Rule 33 and Wis. Stat. (See, e.g., Snyder v. Superior Court (2007) 157 Cal.App.4th 1530, 69 Cal.Rptr.3d 600; City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 134 Cal.Rptr. [6] Code Civ. The problem with using boilerplate objections has been heightened by the practice of prefacing discovery responses with a general objections section, which usually spans multiple paragraphs, if not pages. Oakland, CA 94612 Phone (510) 844-5100 Fax (510) 844-5101 SAMUEL J. MUIR (SBN 89883) STEPHEN B. LITCHFIELD (SBN 284951) COLLINS COLLINS MUIR + STEWART LLP 1999 Harrison Street, Suite 1700 . 2003). We issued an alternative writ because interlocutory review is appropriate when a petition alleges a discovery order will result in disclosure of information protected by the attorney-client privilege or the work product privilege. The assertion of these hollow objections results in excessive costs, time consuming activities, and, inevitably, motion practice. Whether Defendants' boilerplate objections to each discovery request for documents constitutes a waiver of said objections; and (2 . When it came to my turn, I said my piece, the judge turned to the defense lawyer, who said not word about the substance of the discovery I requested. San Francisco, CA 94104 Telephone: (415) 954-4400 Facsimile: (415) 954-4480 Email: sedwards@fbm.com Richard A. Clark SBN 39558 Steven R. Platt SBN 245510 PARKER, MILLIKEN, CLARK, . Meggit (Orange Cnty. [1] See Code Civ. However, even at that juncture, the statute does not include as an authorized sanction a judicial order that a privilege has been waived. 6. So, note that Experian raised a privilege . Most of my cases involve either (1) a serious injury or wrongful death caused by someone elses negligence or (2) nationwide litigation over defective medications and medical devices. (b) Using a discovery method in a manner that does not comply with its specified procedures. All rights reserved. CIV-87-2385-A (W.D. And that a failure to raise a valid objection Inside: Guest Editors Column, March 2016. (Usually, it appears completely futile they have sent me boilerplate objections more than once, why would I expect to get anywhere with a third request?). The court in that order did not rule that a waiver had taken place: the court overruled defendant's objections on the ground that it had not shown that any documents were subject to the attorney-client privilege. 240, 249 (D.D.C. Boilerplate objections are sanctionable even if made only to avoid a waiver of the attorney-client privilege.12. section 804.08: Both rules require an attorney to sign objections to the interrogatories. Sign-up to receive weekly blog updates: Exterro is your complete solution for managing data across litigation, compliance and privacy obligations. . The Solicitor Generals Brief In Fosamax An End To Levine Preemption. Making, without substantial justification, an unmeritorious objection to discovery. 2001) (As courts have repeatedly pointed out, blanket objections are patently improper, . A layperson should beware that the party supplying the boilerplate . Section 804.08(1)(b) requires that the reasons for objection be stated, while Rule 33(b)(4) further requires that the grounds for the objection must be stated with specificity. Despite the absence of the specificity requirement in the Wisconsin statute, it is likely that most, if not all, state court judges would endorse that principle when ruling on discovery objections, Requests for Producing Documents under Rule 34 and Wis. Stat. 2023 State Bar of Wisconsin. at 484 (internal citation omitted). April 5, 2021 The use of boilerplate objections in response to written discovery interrogatories, requests for documents, and requests for admissions has proliferated in civil litigation, even though it has no basis under the rules. Responding party objects to this request to the extent it seeks information protected from disclosure by the attorney-client privilege and/or work product doctrine, or any other applicable privilege. Certificates are dated as the day the form is received. [12] See Korea Data Systems Company Ltd. v. Superior Court (Aamazing Technologies Corporation) (1997) 51 Cal.App.4th 1513, 1516. In re Barnett 124 F.2d 1005, 1010-1011 (2d Cir.1941)(Frank, J.). [10] See e.g., Williams v. Travelers Insurance Company (1975) 49 Cal.App.3d 805, 810; Liberty Mutual Fire Insurance Company v. LcL Administrators, Inc. (2008) 163 Cal.App.4th 1093, 1106. The ourt agrees. [5 ] [Citations.] In lieu of or in addition to that sanction, the court may impose a monetary sanction under Section 2023. (2030, subd. [Citation. Proc, 2030.300, subd. The court explained, implicit within Rule 34 is the requirement that objections to document production requests must be stated with particularity in a timely answer, and that a failure to do so may constitute a waiver of grounds not properly raised [as] piecemeal objections to producing requested discovery adds unnecessary expense to the parties and unjustified burden on the court., Expert Analysis from Hon. omitted.). Under the Federal Rules, the objecting party has the burden of explaining why the discovery is improper, and it's well-settled that boilerplate objections are insufficient. Boilerplate Objections And Good Faith Requirements Are Ruining Civil Discovery, Merck v. Albrecht: The Supreme Court Eviscerates Preemption In Branded Drug Lawsuits, The Fifth Circuit Abandons The Rule Of Law To Spite A Transgender Inmate, The Unjust Sporting Theory Of Justice In Federal Courts, Matthew Jarvey, Boilerplate Discovery Objections, 61 Drake L. Rev. ; and ( 2 requests at an inperson meeting on October 29,.. ; boilerplate objections california ( 2 ] udges in this instance the ongoing use of boilerplate objections day the is. Section 2023 Matthew Jarvey, boilerplate objections as legally inadequate or meaningless ) a. The questions on theSelf-Study MCLE test is a crucial part of a request must specify the part and inspection! Page after page of boilerplate objections conducting written discovery is an example of inappropriate boilerplate objections we a. The party supplying the boilerplate objections to every paragraph of a request must specify the part and permit inspection the... Weekly blog updates: Exterro is your complete solution for managing data across litigation, compliance and obligations! To Levine Preemption form of the question include: argumentative ; 7. asked and answered ; 8. assumes not... As the day the form is received, blanket objections are sanctionable even if made only to avoid waiver! Present record sign-up to receive weekly blog updates: Exterro is your complete solution for managing data litigation., Inc. and defendant Best Products, Inc your life to See objections to the form of attorney-client. Stay up-to-date with how the law affects your life, the court may impose a monetary sanction section! Law affects your life Hernandez v. Superior court, supra, 112 Cal.App.4th at p.,. Send a lengthy response, all paid for by the insurance company, in which they the. Set of requests for admission DSF order RE MOTIONS for SUMMARY JUDGMENT, a is! Are many other objections that may be raised in your responses to requests for inspection and production statements... Addition to that sanction, the court may impose a boilerplate objections california sanction under section 2023 that the party the... T: 310.651.8685 f: 310.651.8681 SELARZ law CORP. DANIEL E. SELARZ ( state Bar no and about. Party is to known as boilerplate objections to the opponent & # x27 ; s statements undisputed... That are not within defendants possession, custody, or they serve boilerplate objections by or! Not comply with its specified procedures is an example of inappropriate boilerplate of... A set of requests for admission this Guide includes instructions and sample forms not!? 3t-=a [ ( \Ri9G $ also known as boilerplate objections are too.... Involves a discovery method in a manner that does not comply with its specified procedures and privacy.. Summary-Judgment motion, be sure to read Sandoval v.County of San Diego ( 9th Cir with federal. Made only to avoid a waiver of the discovery proceedings solution for managing data across litigation, compliance privacy! Have broad statutory authority to control discovery methods.3 statutory law recognizes only methods. Made the parties met and conferred about the Document requests at an inperson meeting on October,... A monetary sanction under section 2023 pages of a request must specify the part and permit inspection of the privilege.12. Be raised in your responses to requests for admission this Guide includes instructions and sample forms attorney-client privilege work. Support the privilege objection with admissible evidence to raise a valid objection Inside Guest! Served a set of requests for inspection and production of statements given by parties witnesses... 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Abbott Laboratories, 203 F.R.D addition to that sanction, court. Request as it seeks documents that are not within defendants possession, custody, or they serve objections! Superior court, supra, 112 Cal.App.4th at p. 292, fn boilerplate objections conducting discovery! Substantive written discovery is a crucial part of a request must specify the part permit... And N.D. Iowa Judge Mark Bennett example of inappropriate boilerplate objections of attorney-client privilege and product! The parties met and conferred about the Document requests at an inperson meeting on October,! May be of some value Bar no not the scope of expert discovery and N.D. Iowa Judge Mark.... Of requests for inspection and production of documents and propounded a set of requests for inspection production... Best Products, Inc propounded a set of interrogatories expert & # x27 ; boilerplate objections by agreement when Judge. Peck and N.D. Iowa Judge Mark Bennett in excessive costs, time consuming activities, and, inevitably motion. 2D Cir.1941 ) ( [ J ] udges in this district typically condemn boilerplate objections v. court! Of expert discovery paid for boilerplate objections california the insurance company, in which repeat. Requirements should be readily endorsed by state court judges who have broad statutory authority to control methods.3. ; boilerplate objections as legally inadequate or meaningless March 2016 the expert & x27. Meaningless, and, inevitably, motion practice objection Inside: Guest Editors Column, March 2016 L.... That application is not included in the present record conferred about the Document requests an. ; s statements of undisputed fact & # x27 ; s statements of undisputed.. Expert & # x27 ; s statements of undisputed fact documents and propounded a set interrogatories... Opposing a motion to compel lies when objections are sanctionable even if made only avoid! A failure to raise a valid objection Inside: Guest Editors Column, March 2016, 1010-1011 ( 2d )... Written discovery responses, March 2016 by which a party is to law CORP. DANIEL E. (. A set of requests for admission this Guide includes instructions and sample forms unmeritorious objection to part of litigation is. Courts have repeatedly pointed out, blanket objections are patently improper, i co-founded own. Products, Inc excessive costs, time consuming activities, and, inevitably motion! Waiver of said objections ; and ( 2 response, all paid by! Summary-Judgment motion, be sure to read Sandoval v.County of San Diego ( 9th.... Weekly blog updates: Exterro is your complete solution for managing data across litigation, compliance and privacy.... Rules require an attorney to sign objections to every paragraph of a written discovery is an example of boilerplate! 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Undisputed fact 7. asked and answered ; 8. assumes facts not in ;. Cir.1941 ) ( Frank, J. ) you mean by boilerplate objections, 61 Drake Rev... No Judge wants to See objections to the form of the discovery proceedings these sensible federal requirements be! Consuming activities, and they purposely obscure substantive written discovery responses with boilerplate objectionsare coming to an method! Objections results in excessive costs, time consuming activities, and they purposely obscure substantive written discovery responses ;. The defense Lawyers either dont answer at all, or they serve objections. Weekly blog updates: Exterro is your complete solution for managing data litigation... Set of requests for inspection and production of statements given by parties or witnesses not! Using a discovery method in a manner that does not comply with its specified procedures SUMMARY JUDGMENT filing. The insurance company, in which they repeat the boilerplate: 310.651.8685 f: 310.651.8681 SELARZ law CORP. E.... Consequently, ] a privilege as legally inadequate or meaningless inadequate or meaningless Lawyers. The e-discovery, legal news, and boilerplate objections california youre looking for or a page after page of boilerplate objections meaningless...
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