objections to interrogatories texas

Objecting to a discovery request on the grounds that it is overly broad presents both a challenge and an opportunity. 189 0 obj <> endobj E-mail: info@silblawfirm.com, Beaumont Office Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. Objections like this are meant to prevent testimony from becoming confusing. endstream endobj 334 0 obj <>stream {u-,gVP#'{W@=Q6o""u7l!R;_WC[eTb0aa,KQbZS#vuJ#n,Gz^rDGZg^W~nKp4Kd8 The number of interrogatories is further limited by the fact that, according to Texas Rules of Civil Procedure 190.3 (B)(3), the discrete subpart of an interrogatory is actually counted as a separate interrogatory. I hope these sample workers compensation interrogatories save you time and help you maximize your claims value. 0000003211 00000 n (Boy, you are behind the 8-ball if this is your answer but we have made this response before. E-mail: info@silblawfirm.com, Dallas Office To satisfy this burden, you should state your objection with specificity. An attorneys thought processes and mental impressions are usually protected and not discoverable. Discovery battles are time-consuming and annoy judges. Moreover, the defendant has failed to demonstrate a substantial need and the substantial equivalent of which the defendant would be unable to obtain by other means without due hardship. 0000036397 00000 n 8000 IH-10 West, Suite 600 Working with a lawyer familiar with the many complexities of interrogatories will minimize the time, money, and effort spent responding to interrogatories during discovery. 6=290`5LnmK*WB. 0000002798 00000 n Electronic and Magnetic Data Each interrogatory should consist of a brief, simple, direct, and unambiguous question, dealing with one point only. 26(b)(1); or (2) is of such marginal relevance that the potential harm occasioned by discovery would outweigh the ordinary presumption in favor of broad disclosure. Telephone: 214-307-2840 In addition, the Elsewhere 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. Information Unknown or Not in Possession of Responding Party You may find this objection is justified if an interrogatory asks for personal information or details of your financial condition that is unrelated to the claims subject matter. Telephone messages will not be taken by the judge's staff. I understand that submitting this form does not create an attorney-client relationship. Martin with their fishing expedition objections. Rule CV-1. Certain limitations on discovery are in place to avoid the misuse of discovery which can overburden the involved parties, wasting time and financial resources in the process. Plaintiff objects to this interrogatory because the defendant had exceeded the number of interrogatories allowed by Maryland law. 0000002779 00000 n Seeking information from social media accounts is becoming commonplace in litigation. Rule 37 (a) (1) mandates that any motion to compel discovery must include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to Further, you do not waive any objection based on privilege or work product by failing to raise it within the time prescribed by the courts rules. 0000004682 00000 n Civil litigation in Texas has three basic phases: Pre-trial, Trial, and. 0000005069 00000 n -1!o7! ' General objections are a list of objections that some defense attorneys especially insurance defense attorneys like to include with their clients answers to interrogatories. Legal Assistance for Black-Owned Businesses. 0000005461 00000 n Telephone: 817-953-8826 o})Lle,S]&s*giBi $^gr@,4O\UDiaDr'Y{ :U8b nzL1$[ t.7crYo{W8j%X{OBp !gRqJ*J#/&CaXI;:X#84( [3c0g8qS eg63^fTdX`pa_`4``2c` g )p E-mail: info@silblawfirm.com, Austin Office ), Plaintiff objects to the entirety of this request because it is not reasonably calculated to lead to admissible evidence. But just because they ask doesnt mean you have to answer. S., Ste. If you object to an interrogatory on the ground that it is too expensive to respond, there are things you can do to make it more likely the court will accept your position. 250 endstream endobj 331 0 obj <>stream 0000036406 00000 n Keep reading to learn more about answering interrogatories and what objections you can use to increase or preserve your cases value and protect your privacy. WebInterrogatories are written questions; The receiving party must respond in writing to the interrogatories and may assert any applicable objections; Responses to interrogatories must be truthful and complete (and are made under oath); and There may be limits on how many interrogatories are allowable in your jurisdiction. Practically, discovery objections also allow you to avoid answering difficult questions. Corpus Christi, TX 78401 Houston, TX 77018 0000001481 00000 n The information or documents will be made available for review at their storage location during business hours at a mutually convenient time. and Towson; Carroll County including Westminster; Frederick County including Frederick; Harford County including Abingdon, Bel Air, Belcamp, and Forest Hill; Montgomery County including Germantown and Rockville; Howard County including Ellicott City and Columbia, Washington, D.C. and Washington County including Hagerstown. So the responding party reserves the right to supplement these responses at trial. WebUnless he applies for a protective order, he is required to serve answers or objections in response to the interrogatories, subject to the sanctions provided in Rule 37(d). Under Rule 33(b)(3) of the Federal Rules of Civil Procedure, a responding party must serve its answers and any objections to interrogatories within 30 days after being served. Gone are the situations when one party could seemingly harass the other party with impunity by serving dozens of irrelevant and burdensome written questions during the discovery process. R. Civ. For more information and a consultation with a top-rated injury lawyer, call me: (804) 251-1620 or (757) 810-5614. An interrogatory is overbroad on its face if it uses the words all or every. For example, an interrogatory asking for all persons with information relevant to the action, every document mentioning your injuries, finances, or accident, or each injury youve suffered in the past is objectionable. 189 43 Out of these cookies, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. In federal court, you have more time to object to interrogatories. This article provides guidance on countering objections arising during discovery in Florida state actions. 0000043729 00000 n interrogatories , and waive tire Despite being directly in conflict with the spirit of the Rules of Civil Premature Request %PDF-1.6 % Interrogatories should not require a party to provide a narrative account of his case., 5. R. 33 (A) (3). 0000007074 00000 n You can object to an interrogatory if the information sought is known by the requesting party or available to both parties equally. The focus of this series is the various issues which cause objections during the discovery process, outlined below: A common Webboilerplate objections to discovery requests.3 Usually, boilerplate objections are found in responses to interrogatories under Federal Rule of Civil Procedure 33,4 or in requests for production of documents under Federal Rule of Civil Procedure 34.5 But they can be found in nearly any pretrial document that might contain an objection.6 0000007315 00000 n Irrelevant. Overbroad or shotgun interrogatories. Theres no statutory provision for objecting on the ground that interrogatories are too broad, but courts use this objection to refer to interrogatories that request, e.g., Annoyance, embarrassment, oppression. Unreasonably cumulative or undue burden and expense. More items In that case, the plaintiff directed interrogatories toward one of two defendants regarding whether any video surveillance had been taken of her. Fax: 469-283-1787 Obtaining social media discovery, however, can pose significant challenges, as this information can take many forms, involve different file types, be generated by different users and be extremely voluminous. You have to respond to interrogatories in writing to the best of your ability. If you do not answer an interrogatory question, and then the other side learns that you did in fact know the answer, it could have a negative impact on your case at trial. The other side could imply that you are trying to hide information that is harmful to your case and ask that an inference or assumption is made 2925 Richmond Avenue, The question should be objective and non-argumentative. <<63C40AC0B7D49E40B7F0030E83088B82>]>> Documents Already Produced In fact, no defense attorney has forced the issue in my cases. 0000003067 00000 n State objections simply Because work product is not a proper objection to contention interrogatories, the trial court had no discretion and could only overrule Volas work I am the attorney editor for California Civil Discovery Practice. Legal advice can only be with knowledge of the clients specific facts. Pursuant to both C.R.C.P. Any CEB publication cited is not intended to describe the standard of care for attorneys in any community, but rather to be of assistance to attorneys in providing high quality service to their clients and in protecting their own interests. Further, an interrogatory might be overbroad if it fails to limit the time it concerns. Protect Your Case with Interrogatory Objections, Be careful about hoping the other side will not force you to answer a proper interrogatory. If the defendant has an attorneywhich is quite likely, especially if the defendant has auto insurancethen its a virtual certainty that the defendant has spoken to their attorney about the collision. endstream endobj 320 0 obj <> endobj 321 0 obj <> endobj 322 0 obj <>/ProcSet[/PDF/Text]/ExtGState<>>> endobj 323 0 obj <> endobj 324 0 obj <> endobj 325 0 obj <> endobj 326 0 obj <>stream How Much Time Do I Have to Object to an Interrogatory? Also available is a version of the interrogatories with electronic "forms" that can be filled in. Xf]],b|EIX~~k rI)Qb*9VN@7qq 8ZVd6E9%p86>. 5 7>00Y If you have additional questions, please dont hesitate to email us. September 21, 2017. The other party must force answers to your interrogatories. Beaumont, TX 77706 Theres no statutory provision for objecting on the ground that interrogatories are too broad, but courts use this objection to refer to interrogatories 0000020446 00000 n Objections that may be used in the course of discovery include, but are not limited to the following: Unduly burdensome, Overly broad Vague Ambiguous Disproportional Protected by the attorney-client privilege Work product doctrine Sometimes, these objections may be asserted and no response provided. <<7F1D1753F15E094A871993BC5086A2C4>]>> 18.001 "Affidavit Concerning Cost and Necessity of Services" Copyright 2017 Corey Pollard | Virginia Workers Compensation Lawyer & Social Security Disability Attorney in Richmond, VA, Guide to Using Objections in Responding to Interrogatories, Objections to Interrogatories in Personal Injury Law, A Lawyers Guide to Deciding Whether to Answer or Object to an Interrogatory in Civil Litigation. If you or your client has won a judgment, you will need a lawyer with specific experience And no judge or deputy commissioner has forced my client to turn this over. Do not try to answer an interrogatory prematurely if more information is needed. WebTexas Rules of Civil Procedure: Rule 168. on 12 Grounds for Objecting toInterrogatories, Click to share on Facebook (Opens in new window), Click to share on Twitter (Opens in new window), Click to share on LinkedIn (Opens in new window), Click to email a link to a friend (Opens in new window), Click to share on Reddit (Opens in new window), Click to share on Tumblr (Opens in new window), How to Drop a Prospective Client Who Doesnt Pay YourRetainer, Checklist: Procedures for Interrogatories | CEBblog, Should You Amend Your Interrogatory Responses? The process of discovery itself allows for the exchange of relevant facts and information about the case, and in the process many cases are settled out of court. The court may sanction you, assessing a fine and court costs. 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. 0 d Answers and Objections to'Discovery and Enforcement of Judgment" Texas Civil Practice and Remedies Code: Sec. Plaintiff objects because the answer to this question may violate the defendant's protection against self-incrimination. This is one of the silliest objections we see. 14th Floor This article provides an overview of what you should consider when you receive interrogatories. Posted on 26 Feb in delores winans grandchildren. In general, when the question asks for information that is not clearly connected with the primary interrogatory, that subpart to the question could be considered a separate interrogatory. Second, you might want to object to avoid answering a tough question that harms your case. Telephone: 210-714-6999 By Daniel Garrie / Law & Forensics LLC. WebThe interrogatory responses in Duffy And despite Defendant Twos objections, invoking the privilege is appropriate even when a party is simply quizzed on the veracity of previous statements. Each approved interrogatory counts as one question. You will likely get objections to your interrogatories. 0000045479 00000 n This means you must answer all the questions asked in interrogatories. The legal conclusion objection is rarely a valid objection. Personal, Constitutional or Property Rights WebR. 777 Main Street, Ste. But defense lawyers love them. (LogOut/ Other CEBblog posts you may find useful: The Regents of the University of California, 2018. 0000008284 00000 n The events which prompted these new amendments to TUTSA were twofold in nature: (1) Congress passed the Defend Trade Secrets Act in May 2016; and (2) the Change), You are commenting using your Facebook account. 0000001733 00000 n 0000006404 00000 n General objections are a list of general objections that presumably apply to all responses to the discovery requests. Fax: 817-231-7294 But a big part of interrogatories is throwing out a big net to capture all the information that is out there that you may not have even considered. WebEach interrogatory shall be answered separately and fully in writing under the penalties of perjury, unless it is objected to, in which event the reasons for objection shall be stated in lieu of the answer; each answer or objection shall be preceded by the interrogatory to which it responds. BoyarMiller uses cookies to enhance your experience on our website. 2. Interrogatories may relate to any matters which can be inquired into under Rule 26(b), and the answers may be used to the extent permitted by the rules of evidence. PAGE Boilerplate Objections Under Rule 193.2(e), an objection that is obscured by numerous unfounded objections is waived unless good cause is shown [This gives you some cover with the jury if you change an interrogatory answer. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); Enter your email address to subscribe to this blog for free and receive notifications of new posts by email. (This is usually a defendant's objection, actually. WebAs is often the case, the plaintiffs served a simple interrogatory seeking OSI information. Permissibility of Discovery Tool As is also often the case, rather than simply providing the requested information, the defendants in this hypothetical have attempted to stonewall plaintiffs by filing obstructionist objections. 0000009608 00000 n Unless Otherwise Noted, Our Lawyers Are Not Certified by The Texas Board of Legal Specialization.Chairman - Chris Hanslik. Each 0000000736 00000 n (b) If an objection is made to a request or to a part of a request, the specific ground for the objection shall be set forth clearly in the response. Plaintiff objects to this interrogatory because it contains a compound, conjunctive, or disjunctive questions. 319 22 Contact Seth Kretzer for Help with Post-Judgment Discovery in Texas. 26(b)(1), any discovery sought must be likely to lead to the discovery of admissible information (which, to be admissible, must be relevant). 340 0 obj <>stream 0000005926 00000 n Co., 2008 WL 2668301 (D. Colo. July 1, 2008). Pursuant to both C.R.C.P. We also use third-party cookies that help us analyze and understand how you use this website. She has not fully completed discovery and has not completed trial preparation. 0000001639 00000 n San Antonio, TX 78230 That defendant objected to the interrogatories as violating the work product doctrine. 0000038535 00000 n Plaintiff objects to this interrogatory because it requires the responding party to marshal all of its available proof or the proof the party intends to offer at trial. WebInterrogatory No. Relevancy is broadly construed under the rules, and C.R.C.P. You have 21 days after the service of the interrogatories to object. Inconvenient Time or Place What Happens if I Dont State an Objection? Attorneys using CEBblog should research original sources of authority. Telephone: 512-501-4148 Fort Worth, TX 76102 Vagueness, Lacks Specificity, or Ambiguity of Request [But the. E-mail: info@silblawfirm.com, Corpus Christi Office !QHn Fed. Telephone: 817-953-8826 Objections to Written Discovery Requests: Overly Broad, An overly broad discovery request lacks specificity as to time, place, and/or subject matter being requested. Seeks Admission of Hearsay The court can order monetary, issue or evidence sanctions for a partys failure to respond in good faith to any interrogatory, request for admission or request for 0000006762 00000 n Both plaintiffs and defendants use them to gather information and develop facts to negotiate a favorable settlement or win at trial. Objections to part of request; Grounds for objections (a) If only a part of a request for admission is objectionable, the remainder of the request shall be answered. ], Plaintiff objects to this question as premature. Don Herring Ltd., 327 F.R.D. Whether the information sought is vital to resolving the legal dispute. The producing party has the burden to provide sufficient detail in terms of time, money and procedure required to produce the requested documentsunless it is obvious from the wording of the request itself that it is overbroad, vague, ambiguous or unduly burdensome, an objection simply stating so is not sufficiently specific. City of Seattle v. Profl Basketball Club, LLC, 2008 WL 539809 (W.D. Web3. Rule 33 (Interrogatories to Parties) also requires specificity when making objections. E-mail: info@silblawfirm.com, Austin Office Webobjections to interrogatories texas objections to interrogatories texas. An interrogatory is improper if it asks for pure speculation based on hypothetical facts without foundation or requests an answer to a question based on a wrong assumption. 4320 Calder Ave. As to the person or persons who participated in responding to HR&c?5~{5ky\g} %PDF-1.6 % 145 0 obj <> endobj xref 145 22 0000000016 00000 n Number of Interrogatories In contrast, a Level 2 case permits more interrogatories (as many as 25) and places no limit on the number of requests for production or admissions allowed. 0000002146 00000 n 0000043163 00000 n There are many grounds to object to interrogatories. 250 There are two types of witnesses expert witnesses and lay witnesses. 710 Buffalo Street, Ste. (Get details on the Austin, TX 78746 Overly Broad The following endstream endobj 330 0 obj <>stream 0000007739 00000 n 0000001156 00000 n WebDISCOVERY OBJECTIONS CHEAT-SHEET. H|Ao G`7rk"JzRV>{7,\7q-/Ri$( 7(O/ Od&C:b}_"S*PPBBM Qv.r90vQF75_~%V\`A"$9}|J1yEiV2 M1cmJzH?# 0000004121 00000 n 2) Specify its legal or factual basis. This discovery request is so broad and unlimited as to time and scope as to be an unwarranted annoyance, embarrassment, and is oppressive. The focus of this series is the various issues which cause objections during the discovery process, outlined below: Introduction E-mail: info@silblawfirm.com, Fort Worth Office 0000009903 00000 n Should I Answer the Interrogatory Even if I State an Objection? Plaintiff objects to this interrogatory because it seeks information in the possession of, known to, or otherwise equally available to the plaintiff. Corpus Christi, TX 78401 0000041378 00000 n For example, you should raise this objection if the answers are publicly available or in a third-partys custody or control. You waive any objection to written discovery if you fail to state it in time. Plaintiff objects to this interrogatory because this interrogatory calls for privileged information within the attorney-client privilege that it seeks information that is in the attorney's work product. 1. xb```f`` |@1X t+]HX7r-=rL * ) 3XZ${KKo& xb```"SVs eah`\v&.&Xp}a4m9ursq`+Tb>q#k!)v;ji"l/&-|y5K#&FXvMLs-}/8Lb# Some judges will require the party reading the answer to the jury to also read the objections. In the first sentence of Rule 193.3(b), the word "to" is deleted. So here are some sample interrogatory objections, a cheat sheet that might help you determine how to object to interrogatories (that can also be applied to other discovery objections): The most common discovery objection our lawyers see is the objection that the interrogatories are not relevant to the litigation or are too burdensome to answer. This request is overbroad, and it constitutes an abuse of the discovery process, because it purports to ask [Producing Party] to plead and prove its entire case, and to marshal all evidence, in response to one written interrogatory. 231 0 obj <>stream Users of this website should not take any actions or refrain from taking any actions based upon content or information on this website. But just because the opposing party serves you with interrogatory requests doesnt mean you have to answer all the questions. Lacks Specific Description within Request, Vagueness, Lacks Specificity, or Ambiguity of Request, Information Obtainable from Another Source, Information Equally Available to the Other Party, Request Creates Unnecessary Burden, Expense, or Made for Purposes of Harassment, Personal, Constitutional or Property Rights, Information Unknown or Not in Possession of Responding Party, Request Seeks Admission of a Legal Proposition, Introduction to This Series About Objections During Discovery, Discovery Objection Because the Information Is Equally Available to the Other Party, Protecting Your Property with a Right of First Refusal in Your Texas Estate Plan, Caring for Your Home When Your Co-Owner is an Absentee, Landlord Liability For Breach of Lease in Texas, Proposed Federal Trade Commission Non-Compete Ban. You can object to interrogatories on many grounds. Heres a list of objections to keep handy when the next batch of interrogatories arrives. Irrelevant. Interrogatories must be relevant to the subject matter of the action or appear reasonably calculated to lead to the discovery of admissible evidence. Any ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure.". Information Unknown or Not in Possession of Responding Party Fed. 2030.060(d) (interrogatories). The other party may ask about past criminal convictions to attack your credibility or likability. [] 12 Grounds for Objecting toInterrogatories [], [] 12 Grounds for Objecting to Interrogatories []. WebThese interrogatories are intended to provide for the exchange of relevant information without unreasonable expense to either party. 3) Describe the extent to which you refuse to comply with the You might have a valid reason for objecting to the interrogatory or limiting your response. Persons with Knowledge of Relevant Facts Fax: 469-283-1787 0 0000000016 00000 n The contact form sends information by non-encrypted email, which is not secure. 0000045867 00000 n This information should in no way be taken as an indication for future results. What are the Most Common Objections to Interrogatories? DEPOSITIONS IN FOREIGN JURISDICTIONS FOR USE IN TEXAS PROCEEDINGS; DEPOSITIONS IN TEXAS FOR USE IN FOREIGN PROCEEDINGS ..54 201.1 Depositions in Foreign Jurisdictions for Use in Texas Proceedings ..54 201.2 Depositions in Texas for Use in Proceedings in Foreign Jurisdictions 56 RULE 202. See U. S. v. Wilcox, 450 F.2d 1131, 1141 (5th Cir. Interrogatories are a vital discovery tool used in civil litigation, including workers compensation, tort, and car accident cases. Webobjection to or other failure to answer an interrogatory. State courts in Virginia followthe same rules. (yvrXJ2TYBFW/1U>YS)YQmKg{1f.uMa7ebi$x!=-6^-N7{BAE!MC@\ 7t!M` pzTx|}j3%Db#7cxbxFhn0EnO;>E"Ff|"WH}Wg kg'fM dmU@~hRT x " If investigation is continuing or if discovery is not yet complete, the interrogatory shall nevertheless be responded to as fully as possible at the time the response is due. 0000003287 00000 n Moreover, [a]n objection to an interrogatory shall be made by stating the objection and the reason therefore either in the space following the 3. 0000009081 00000 n 802 These cookies do not store any personal information. The focus of this series is the various issues which cause objections during the discovery process, outlined below: Introduction You can interpret the question narrowly and respond. September 21, 2017 BoyarMiller attorney Whitney Brieck discussed evolving trends in how Texas courts are applying the Texas Rules of Civil Procedure to streamline Webing said objections, plaintiff responds as follows Objecting to interrogatories A Pulitzer has never been awarded for objections to written discovery. Analyze both routes and the impact your choice will have on the ultimate goal: winning your case and getting more money for your losses. trailer In Back to Basics: Requests for S., Ste. 108 Wild Basin Rd. Plaintiff objects because this interrogatory calls for pure conjecture and speculation. Each Fort Worth, TX 76102 Documents Already Produced Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. 0000002727 00000 n endstream endobj 59 0 obj<> endobj 61 0 obj<> endobj 62 0 obj<>/Font<>/ProcSet[/PDF/Text]/ExtGState<>>> endobj 63 0 obj<> endobj 64 0 obj<> endobj 65 0 obj<> endobj 66 0 obj[/ICCBased 71 0 R] endobj 67 0 obj<> endobj 68 0 obj<> endobj 69 0 obj<> endobj 70 0 obj<>stream Fax: 817-231-7294 802 Level 1 discovery control plan, for example, is limited to no more than 15 interrogatories, admissions, and requests for production. Fill in your details below or click an icon to log in: You are commenting using your WordPress.com account. The changes This interrogatory is overly broad and unduly burdensome because it requires [Producing Party] to create and provide the equivalent of a lengthy narrative or otherwise detailed account, witness by witness, of its entire case. 0 Houston Office WebCounsel should draft interrogatories as simply and clearly as possible to minimize objections and to elicit meaningful responses from the responding party. They should not seek narrative answers or attempt to argue, cross-examine, or impeach.Hilt v. SFC. Plaintiff objects to this interrogatory in that it requests information that will not be known until after additional discovery is completed. H_O0b|hL4K}2>6l'-YXVxi=r It covers the timing, Houston, TX 77018 0000014400 00000 n Privilege Assertions of Privilege. It is mandatory to procure user consent prior to running these cookies on your website. Under Maryland law, this onus is on the party receiving the objection to force the issue. Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. Thus, when objecting to discovery on the grounds that it is overly broad and lacking relevance, be prepared to demonstrate that the requested discovery either (1) does not come within the scope described in Fed.R.Civ.P. Each interrogatory shall be responded to as fully as possible at the time of response. The court commented, Whenthe answer is to be made in writing, after due time for deliberation and consultation with counsel, an answer may be framed which avoids the pitfalls, if any, inherent in the form of the question. So, the best response to an interrogatory that assumes a disputed incident occurred is to simply state that there is a dispute regarding the named incident and then answer the interrogatory to the extent it requests information that does not require you to buy into the opposing counsels disputed version of events. However, overbroad is not a valid objection unless it can be shown that the request imposes an undue burden or seeks discovery that is not relevant to the subject matter of the case.
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