Discovery Objections Cheat Sheets: Full Guide

What Are Common Objections to Discovery Requests?

Here’s a breakdown of common discovery objections and when they apply:

1. Relevance

A relevance objection is used when a discovery request seeks information that has no connection to the claims or defenses in the case.

Courts generally allow broad discovery, but requests must still be reasonably related to the legal issues at hand. If a request asks for irrelevant, outdated, or unrelated information, you can object on these grounds.

However, it’s important to explain why the request is irrelevant rather than just stating the objection.

Example: “Objection. The requested documents concern events that occurred outside the relevant time frame and have no bearing on the issues in dispute.”

Remember: A strong relevance objection should specify why the request is irrelevant while still complying with discovery obligations where necessary.

2. Overbroad and Unduly Burdensome

An objection for being overbroad and unduly burdensome comes into play when a discovery request isn’t clear, asks for too much, or takes way too much time and effort to respond to.

Courts allow broad discovery, but they also expect requests to be reasonable. If a request doesn’t set clear limits on time, subject matter, or scope, it can turn into a massive task that eats up unnecessary resources. But just saying a request is “too broad” isn’t enough—courts want to see why it’s a problem.

Example: “Objection. This request is overbroad and unduly burdensome as it seeks ‘all documents’ related to the matter, without any reasonable limits on time or subject.”

If only part of the request is overbroad, you should respond to the reasonable portion while objecting to the rest. Courts prefer narrowing requests rather than outright refusal, so offering to meet and confer can help avoid disputes.

3. Privileged Information

An objection for privileged information is used when a discovery request asks for materials protected by attorney-client privilege, work product doctrine, or other legal protections.

Courts take privilege seriously, but objections need to be specific—you can’t just claim privilege without explaining why the information is protected. If you withhold documents, you’ll likely need to provide a privilege log listing what’s being withheld and why.

Example: “Objection. This request seeks information protected by the attorney-client privilege and is therefore not subject to disclosure.”

If only part of the response is privileged, courts expect you to produce the non-privileged portions while redacting the protected content.

Keeping a detailed privilege log can help avoid challenges and show that you’re withholding information for a valid reason, not just to block discovery.

4. Vague or Ambiguous

An objection for being vague or ambiguous applies when a discovery request is unclear, confusing, or open to multiple interpretations. If the wording is too broad or poorly defined, it can be difficult to know exactly what’s being asked.

Courts expect objections to be reasonable, so if a request can be clarified, it’s often better to ask for clarification rather than refuse to respond altogether.

Example: “Objection. This request is vague and ambiguous as it fails to define the term ‘relevant communications,’ making it unclear what is being sought.”

5. Confidential or Private Information

An objection for confidential or private information is appropriate when a discovery request asks for sensitive business data, personal records, or legally protected material. While courts recognize the need for broad discovery, they also expect parties to protect trade secrets, financial details, medical records, and other confidential data.

Simply labeling something as “confidential” won’t be enough—if the information is relevant, a court may allow disclosure under a protective order to limit who can access it and how it’s used.

Examples: “Objection. The request seeks confidential business records containing proprietary information not subject to unrestricted disclosure.”

Instead of outright refusing, consider discussing possible limitations or safeguards with the opposing party to avoid unnecessary court intervention.

6. Already Available

Courts generally don’t require a party to produce materials that the other side can easily obtain on their own, especially if they’re public records, already in possession of the requesting party, or available from a third-party source.

An objection for already available information applies when the requesting party has equal access to the documents or data they’re asking for.

Examples: Objection. The requested documents are equally available to the requesting party through publicly accessible records.”

If the request involves public or easily accessible records, you can reference where the party can obtain them rather than producing the documents yourself.

7. Calls for a Legal Conclusion

A discovery request asks, “Do you admit that the defendant was negligent in causing the accident?” This type of question isn’t just seeking facts—it’s asking for a legal analysis that only a judge or jury can decide.

Discovery is meant to gather factual information, not force a party to make legal conclusions. When a request crosses that line, it’s appropriate to object.

Examples: “Objection. This request calls for a legal conclusion and is therefore improper under the rules of discovery.”

8. Compound Request

An objection for compound requests or compound questions is appropriate when a discovery request combines multiple inquiries into one, which makes it difficult to determine exactly what’s being asked.

Requests should be clear and specific, but when a single request covers multiple topics, timeframes, or document categories, it can create confusion or require separate responses.

Examples: “Objection. This request is compound, as it includes multiple separate inquiries that should be broken down into distinct requests.”

When a request includes both clear and unreasonable parts, responding to what makes sense while objecting to the rest is usually the best approach.

9. Calls for Speculation

Speculative questions in discovery are improper because they require a party to guess rather than provide factual information. Requests that ask how someone might have acted under different circumstances or what another person was thinking go beyond what discovery allows.

Courts expect responses to be based on personal knowledge or available admissible evidence, not assumptions.

Example: “Objection. The question asks the responding party to predict actions or thoughts of another individual, which is not proper for discovery.”

If part of the request can be answered with known facts, it’s best to respond to that portion while objecting to the speculative parts. Courts typically reject blanket refusals if any part of the request is reasonable.

10. Calls for an Expert Opinion

Requests that demand technical analysis, medical evaluations, or legal interpretations often fall outside the scope of standard discovery responses. If a question requires specialized knowledge that only a qualified expert can provide, it’s appropriate to object.

Example: “Objection. This request calls for an expert opinion, which the responding party is not qualified to provide.”

If the responding party has relevant expertise, the court may still require an answer. However, if the request truly requires expert input, the appropriate response is to object and refer the matter to expert witnesses designated in the case.

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Discovery responses cost firms $23,240, per year, per attorney. $23,240 estimate assumes an associate attorney salary of $150,000 (including benefits – or $83 an hour), 20 cases per year/per associate, 4 discovery sets per case, 30 questions per set, 3.5 hours spent responding to each set, and 1800 hours of billable hours per year.

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