Read the Rules: Md. Rule 2-402 Discovery Guideline No. Also, be aware that the party seeking the information can obtain discovery of work product materials if they can show a substantial need for the information and that the materials cannot be obtained undue hardship. This does not apply to any documents and/or information shared with an expert witness whom you intend to have testify at trial. For example, this can include your notes that document your analysis or valuation of the case or an outline of your cross-examination of the opposing party. Work Product Doctrine. This objection covers material that was prepared in anticipation of litigation or for trial.If the information sought is in any way related to the issues presented by the case, do your best to answer the request. Irrelevant/Not Reasonably Calculated to Lead to the Discovery of Admissible Evidence. This objection is reserved for those discovery requests that are completely unrelated to the subject matter of the litigation.If a request is truly cost prohibitive, consider seeking a protective order under Md. This objection is reserved for those discovery requests that seek information and/or documents that would be very time-consuming and/or cost prohibitive to locate or produce. Overly Vague and/or Broad. This objection is reserved for discovery requests that are very difficult to comprehend, leave material (meaning important and relevant) terms undefined, or request information that is not limited to the timeframe of the relevant events.If you really feel that a request is objectionable, you can object for one or more of the following reasons: Under the Maryland Rules, a party has the right to obtain discovery on any non-privileged matter that is relevant to the subject matter of the action.ĭo your best to answer each question. When answering discovery, review the discovery material carefully for any objectionable requests. If you do not, you risk sanctions from the court, including the possibility of costs (i.e., a fine) or dismissal of your case. The most important thing to remember when answering discovery is to tell the truth. Contact your local public law library for assistance in locating samples and templates for use in drafting your own document. It may be difficult to find a sample with the exact language you are seeking. A court-approved, fill-in-the-blank form is not available for a consent motion or the proposed order.The Court can also modify your proposed order. The Court may or may not approve your proposed order. A proposed order may be attached to the motion and contains what you are asking the Court to grant.A consent motion means that the other party consents to the request in the motion.
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