Analysis of Defendant Farley Blue-Eyes’ Responses to Plaintiff’s RFPs
Many of the responses are well done and drafted. You can add to the objection to document request no. 1 it is contrary to F.R.C.P. 26(b)(1) which limits discovery to nonprivileged matters only. Since you are claiming that the materials requested here are privileged, F.R.C.P. 26(b)(5) requires you to describe the nature of the materials you are withholding due to attorney-client privilege without divulging the contents of the materials. It is important to state the exact provision that provides for privilege. You can also include the aforementioned recommendation of addition to objections of document requests nos. 15, 18, 19, and 20. You will also be required to show the law that provides for privilege and state the nature of materials that are protected under that privilege without divulging their contents.
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