![]() ![]() Just like you can take advantage of lazy or distracted lawyers by forcing answers to your interrogatories, you can also gain an advantage by not answering interrogatories that are arguably objectionable. ![]() Under Maryland law, this onus is on the party receiving the objection to force the issue. Practically, discovery objections also allow you to avoid answering difficult questions. There are times when you should not give complete answers to an interrogatory because the question is objectionable. If we do not hold defendants' feet to the fire, we toss away a powerful tool to box in defendants for trial - and provide evidence that we are not giving the case the care and attention it deserves.īut this is an adversarial process. This page provides a cheat sheet for discovery objections for lawyers.Įlsewhere on this website, we talk about the importance of forcing defendants to provide meaningful answers to interrogatories, requests for the production of documents, and other discovery responses and requests. 11 26 Sanitation & Recycling Indus., Inc. County of San Luis Obispo, 548 F.3d 1184 (9th Cir. City & County of San Francisco, 196 F.R.D. 18Ĭertain of the Specific Questions and Answers Designated by the Plaintiff Are Also Inadmissible for Various Reasons. 17 Testimony Regarding the Experiences of Foreign Militaries Is Irrelevant. 16 Testimony Regarding Enlistment Waivers for Convicted Felons Is Irrelevant. Testimony Regarding Research and Developments that Occurred After Enactment of 10 U.S.C. 13 At Least Three Specific Areas Inquired into in the 30(b)(6) Depositions Are Irrelevant. 12 The Designated Testimony of the 30(b)(6) Witnesses Is Irrelevant to the Extent it Constitutes the Personal Views of the Witnesses. Presenting Testimony by Six Former Service Members Would Constitute "Needless Presentation of Cumulative Evidence". All of the Contemplated Lay Witness Testimony Regarding the Merits Is Irrelevant in this Facial Challenge. Plaintiff Failed to Disclose the Identities of Eight 8 of its Lay Witnesses as Required by the Rules. MEMORANDUM OF POINTS AND AUTHORITIES TABLE OF CONTENTSĤ INTRODUCTION. 20044 Telephone: (202) 353-0543 Facsimile: (202) 616-8202 Attorneys for Defendants United States of America and Secretary of Defense Department of Justice, Civil Division Federal Programs Branch 20 Massachusetts Ave., N.W. ![]() Respectfully submitted, TONY WEST Assistant Attorney General ANDRÉ BIROTTE, JR United States Attorney JOSEPH H. BOX 883, BEN FRANKLIN STATION WASHINGTON, D.C. 13 Dated: J14 15 16 17 18 19 20 21 22 23 24 25 26 27 28ĭEFENDANTS' NOTICE OF MOTION AND MOTION IN LMINE TO EXCLUDE LAY WITNESS TESTIMONY UNITED STATES DEPARTMENT OF JUSTICE CIVIL DIVISION, FEDERAL PROGRAMS BRANCH P.O. This Motion is made following the conference of counsel pursuant to Local 11 12 Rule 7-3, which took place by telephone on June 8, 2010. The Motion 8 will be based upon these moving papers, the attached Memorandum of Points and 9 Authorities in support of the Motion, and upon such other and further arguments, 10 documents, and grounds as may be advanced in the future. Phillips, United States District Judge, 5 Defendants United States of America and the Secretary of Defense (collectively, 6 "Defendants"), by and through counsel, will move in limine to exclude certain lay 7 witness testimony that Plaintiff intends to offer into evidence at trial. NOTICE OF MOTION AND MOTION IN LIMINE TO EXCLUDE LAY WITNESS TESTIMONY NOTICE IS HEREBY GIVEN that on June 28, 2010, at 2:30 p.m., in theĤ Courtroom of the Honorable Virginia A. UNITED STATES DEPARTMENT OF JUSTICE CIVIL DIVISION, FEDERAL PROGRAMS BRANCH P.O. Notice of Motion and Motion in Limine to Exclude Lay Witness Testimony 2. GATES, Secretary of 18 Defense, 19 20 21 22 23 24 25 26 27 28ĭEFENDANTS' NOTICE OF MOTION AND MOTION IN LMINE TO EXCLUDE LAY WITNESS TESTIMONYįiled herewith: 1. BEFORE: Judge Phillipsġ7 UNITED STATES OF AMERICA AND ROBERT M. CV04-8425 VAP (Ex) DEFENDANTS' NOTICE OF MOTION AND MOTION IN LIMINE TO EXCLUDE LAY WITNESS TESTIMONY DATE: JTIME: 2:30 p.m. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA EASTERN DIVISION Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. 20044 Telephone: (202) 353-0543 9 Facsimile: (202) 616-8460 E-mail: 10 Attorneys for Defendants United States 11 of America and Secretary of Defense 12 13 15 16 v. Department of Justice Civil Division 7 Federal Programs Branch Post Office Box 883 8 Washington, D.C. United States of America et alġ TONY WEST Assistant Attorney General 2 ANDRÉ BIROTTE, Jr. ![]()
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