Discovery Objections Cheat Sheet: Grounds and Examples

This discovery objections cheat sheet covers written discovery only: interrogatories, requests for production, and requests for admission. It does not cover deposition or trial objections.

The quick reference below compares common grounds, the facts that support each one, and the language that is typically boilerplate. For background, see our discovery objections overview. To evaluate the other side’s responses, see how to read common discovery objections.

Federal rules come first. California has its own section so the two systems stay separate.

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Discovery Objections Cheat Sheet: Quick Reference

A defensible objection states the specific ground, ties it to facts, says what is withheld, and answers the rest. The “Still must do” line in each entry below is the part that often gets lost: an objection rarely excuses the whole response.

Federal rules by request type

Interrogatories: Rule 33

Rule 33 sets the baseline for interrogatories:

• Timing: Responses are due within 30 days after service unless the parties stipulate or the court orders otherwise (Rule 33(b)(2)).
• Answer what is not objected to: Each interrogatory must be answered separately and fully in writing under oath “to the extent it is not objected to” (Rule 33(b)(3)).
• Specificity: Grounds for objecting must be stated with specificity, and a ground not stated in a timely objection is waived unless the court excuses the failure for good cause (Rule 33(b)(4)).
• Signatures: The person who answers signs the answers, and the attorney who objects signs the objections (Rule 33(b)(5)).
• Numerical limit: A party may serve on any other party no more than 25 written interrogatories, including all discrete subparts, absent a stipulation or court order (Rule 33(a)(1)).
• Contentions: An interrogatory is not objectionable only because it asks for an opinion or contention that relates to fact or the application of law to fact (Rule 33(a)(2)).

For more examples, see our interrogatory objection examples.

Production: Rule 34

Rule 34 governs requests for production (RFPs). It reaches items in the responding party’s “possession, custody, or control” (Rule 34(a)(1)). The response requirements are specific:

• Reasons: For each item or category, the response must state that inspection will be permitted as requested or state with specificity the grounds for objecting, “including the reasons” (Rule 34(b)(2)(B)).
• Timing of production: Production must be completed by the requested inspection time or another reasonable time specified in the response (Rule 34(b)(2)(B)).
• Withholding statement: An objection must state whether any responsive materials are being withheld on the basis of that objection (Rule 34(b)(2)(C)).
• Partial objections: An objection to part of a request must specify the part and permit inspection of the rest (Rule 34(b)(2)(C)).
• Response time: The default is 30 days after service (Rule 34(b)(2)(A)).

Together, these provisions make a stand-alone general objection followed by a production “subject to” it hard to defend.

Admissions: Rule 36

Rule 36 governs requests for admission (RFAs). Requests may reach facts, the application of law to fact, and opinions about either, plus the genuineness of described documents (Rule 36(a)(1)). The response rules differ from Rules 33 and 34:

• Deemed admitted: A matter is admitted unless a written answer or objection signed by the party or its attorney is served within 30 days after service, or a different time is stipulated or ordered (Rule 36(a)(3)).
• Admit or deny: If a matter is not admitted, the answer must specifically deny it or state in detail why the party cannot truthfully admit or deny it (Rule 36(a)(4)).
• Partial answers: When good faith requires, the answer must specify the part admitted and qualify or deny the rest (Rule 36(a)(4)).
• Reasonable inquiry: Lack of knowledge is a permitted reason only if the party states it has made reasonable inquiry and that the information it knows or can readily obtain is insufficient (Rule 36(a)(4)).
• Objections: The grounds must be stated, and a party may not object solely because the request presents a genuine issue for trial (Rule 36(a)(5)).

Objection examples with supporting facts

The three hypotheticals below are invented for this article. Facts, local rules, and judges’ standing orders change what works.

Federal production request

Assume a federal employment case. The plaintiff alleges a failure to promote in one department. The request reads: “Produce all personnel records for all employees from 2015 to the present.”

A response that follows Rule 34(b)(2)(B)–(C) might read:

This response names the excluded scope, supports the burden claim with facts, commits to a production, and includes a withholding statement. Those burden facts have to hold up: if a court asks how the estimate was reached, someone needs an answer.

Federal interrogatory

Assume a personal injury case. The interrogatory asks: “Describe all incidents involving the Premises.”

“Incidents” could mean prior falls, any police call, or any maintenance event. A response might say:

The answer must still be complete for the stated reading, and under Rule 33(b)(3) the unobjectionable portion has to be answered under oath.

California special interrogatory

This example applies CCP §§ 2030.060(f) and 2030.240. Assume the interrogatory asks: “Identify each witness to the incident and state whether each gave a written statement.” A response might read:

California differences to check

California state-court discovery runs on the Code of Civil Procedure (CCP), not the FRCP. These points are intentionally general:

• Scope: CCP § 2017.010 covers nonprivileged matter relevant to the action’s subject matter or a motion, if admissible or reasonably calculated to lead to admissible evidence. This California wording is not the federal Rule 26(b)(1) standard.
• Interrogatories: CCP § 2030.240(a)–(b) requires a clearly stated specific objection and an answer to the unobjectionable remainder. Identify the particular privilege or expressly assert work-product protection.
• Production: CCP § 2031.240(a)–(c) requires a compliance statement or inability-to-comply representation for the unobjectionable remainder, particular identification of responsive items objected to, and the objection’s extent and specific ground. Privilege/work-product claims require sufficient factual information for evaluation, including a privilege log if necessary.
• Special interrogatories: CCP § 2030.060(d), (f) requires each interrogatory to be complete in itself and prohibits subparts and compound, conjunctive, or disjunctive questions in specially prepared interrogatories. Federal Rule 33(a)(1) instead counts discrete subparts toward its limit.
• Admissions: CCP § 2033.230(a)–(b) requires an answer to the unobjectionable remainder and a clearly stated specific objection. Identify the particular privilege or expressly assert work-product protection.

Other states have their own rules. A reference built on federal or California text does not carry over automatically to Texas, Florida, New York, or anywhere else.

Boilerplate and response mistakes to avoid

The quick reference takes the grounds one at a time. These mistakes cut across all of them:

• Legal-conclusion objections: Rule 33(a)(2) says an interrogatory is not objectionable only because it asks for an opinion or contention relating to fact or the application of law to fact, and Rule 36(a)(1) allows requests about the application of law to fact. The label alone needs more. Pure questions of law, or requests that seek counsel’s mental impressions, are a different matter.
• Equal-access assumptions: “Equally available to the propounding party” is not, by itself, a basis to refuse. Rule 26(b)(2)(C)(i) requires a court to limit discovery that is unreasonably cumulative or duplicative, which governs court-imposed limits without displacing timely, supported objections under Rules 33 and 34.
• Confidentiality as a shield: Confidential information is not automatically exempt. Under Rule 26(c)(1)(G), a court may order, for good cause, that a trade secret or confidential commercial information not be revealed or be revealed only in a specified way.
• Unsupported burden: “Unduly burdensome” with no custodians, sources, volume, or effort estimate gives the other side and the court nothing to evaluate.
• Ambiguous “subject to” responses: Answering “subject to and without waiving” leaves the other side guessing whether anything was held back. Rule 34(b)(2)(C) requires production responses to say whether materials are being withheld.
• Generic general objections: A block of objections applied to every request does not satisfy the specificity requirements in Rules 33(b)(4) and 34(b)(2)(B). Tie each objection to its request.

Our guide to discovery responses shows how these issues fit into a complete response.

Deadline and local-order checklist

Before serving, confirm:

• Response deadline: Check the applicable 30-day trigger, any court order, and Rule 29’s limits on stipulated extensions.
• Local rules and standing orders: The district’s local rules and the assigned judge’s procedures may add formatting, numbering, or objection requirements.
• Protective order status: Check whether a stipulated or court-entered order is already in place.
• Electronically stored information (ESI) protocol: Confirm any agreement on form of production and search terms.
• Privilege log timing: Confirm whether the case schedule or an order sets timing and format.
• State-court rules: If the case is in state court, check that state’s own response deadlines and objection rules.

Draft discovery responses with Briefpoint

Briefpoint drafts responses and objections to interrogatories, requests for production, and requests for admission. Output is editable in Microsoft Word, and attorneys keep final review of every response.

Briefpoint also includes Discovery Playbooks. Attorneys review objection and response language against the matter’s facts and governing rules.

For production responses, Autodoc finds responsive documents, adds page-level Bates citations (Bates numbers are page identifiers), and builds a Bates-numbered production package. Attorneys must independently determine what is withheld and ensure the response complies with Rule 34.

Briefpoint supports all 50 states and 98 federal courts. See plan details on the pricing page. Book a demo to see it with your own discovery requests.

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FAQs About Discovery Objections Cheat Sheet

What are common objections to interrogatories?

Common objections include relevance and proportionality, overbreadth, undue burden, vagueness, privilege or work product, and exceeding the numerical limit. Under federal Rule 33(b)(4), each ground must be stated with specificity, and under Rule 33(b)(3) the portion not objected to must still be answered under oath. A bare label without supporting facts does not meet that specificity requirement.

What are general objections?

General objections are blanket objections placed at the start of a response and applied to every request. Federal Rules 33(b)(4) and 34(b)(2)(B) require objections to be stated with specificity, and Rule 34(b)(2)(C) requires a statement of whether anything is withheld. Objections tied to a particular request fit those requirements better than a generic block.

Can you object that a request calls for a legal conclusion?

Sometimes, but the label alone is thin. Federal Rule 33(a)(2) says an interrogatory is not objectionable only because it asks for an opinion or contention relating to fact or the application of law to fact, and Rule 36(a)(1) permits admission requests on the application of law to fact. The objection is stronger when it identifies a pure question of law or protected counsel analysis.

What supports an overly broad and unduly burdensome objection?

Concrete facts: the date range, custodians, systems or sources involved, volume, and an explained estimate of the effort required. Rule 26(b)(1) weighs burden or expense against likely benefit in the proportionality analysis. Rule 34(b)(2)(B)–(C) then requires the reasons, the part objected to, a statement of anything withheld, and production of the rest.

How do California discovery objections differ?

California uses its own statutory scope and response requirements. CCP § 2030.240 requires specific interrogatory objections and answers to unobjectionable portions; § 2031.240 addresses identification and privilege information for production objections. Section 2030.060 prohibits subparts and compound questions in specially prepared interrogatories, while § 2033.230 governs admission objections and partial answers.

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