Objecting in Interrogatories

When car accident negotiations fail, litigation will follow.  As a Georgia accident attorney, I understand this fully.  When in a personal injury lawsuit in Georgia you have to file and drafts lots of different documents to get the information you are seeking. One way to get information from the opposing party is to send a list of questions which are called interrogatories.  The law firm for the insurance company of the at-fault driver must answer the questions you asked with some exceptions.  If you were to look at a response to a discovery request, you will generally see similar language objecting to potential question because some questions are out of bounds in a Georgia personal injury lawsuit.

(1) Plaintiffs object to each and every interrogatory … to the extent that it would require Plaintiffs to respond by disclosing his attorney’s or other of their representative’s mental impressions, conclusions, opinions, … on the ground that said request exceeds the permissible scope of discovery under the Civil Practice Act.

This is easy and obvious.  If you have been in a car accident, do you think your lawyer must disclose to the other side the strategy of the case or legal theories on who to win or maximize the value of a personal injury lawsuit.  So, if asked these types of questions, an objection will rule the day on that question or questions.

(2) Plaintiffs object to each and every interrogatory, request to produce, and production of documents to the extent that it, whether standing alone or taken in conjunction with any and all requests, is calculated or would operate to annoy, embarrass, oppress, unduly burden, or unduly cause expense to, or would be unduly vexatious or unduly burdensome to respond to, or would require Plaintiffs to engage in investigative efforts burdensome to the point of oppression, on the ground that said request exceeds the permissible scope of discovery under the Civil Practice Act.

Are you starting to see what we are doing here?  Just the basics.  I will answer your questions, but let’s be reasonable and respectful about it.  We are not here to waste the other party’s legal fees, although it is a factor that should be monitored at all times during an Atlanta personal injury case.  Your accident lawyer will understand when the car insurance company is putting their money where their mouth is.

(3) Plaintiffs object to each and every interrogatory, request to produce, and production of documents to the extent that it requires Plaintiffs to respond by acquiring or supplying information which would be irrelevant to the subject matter or issues of this action, and not reasonably calculated to lead to the discovery of admissible evidence, on the grounds that said request exceeds the permissible scope of discovery under the Civil Practice Act.

Plaintiffs object to each and every interrogatory, request to produce, and production of documents to the extent that it requires them to respond by waiving its attorney-client privilege, on the ground that said request exceeds the permissible scope of discovery under the Civil Practice Act.

Everybody in Georgia loves their attorney-client privilege.  You generally think of it more in a criminal case than in a Georgia personal injury case, but you still have it.

Plaintiffs object to each and every interrogatory, request to produce, and production of documents to the extent that the request or preface thereto require supplemental responses by Plaintiffs beyond or in addition to those required by the Civil Practice Act.

After all of the mumbo jumbo the lawyer will typically say the subject to the above restrictions, here are our responses.  This is just a brief intro on the general objections to interrogatories in Georgia car accident and personal injury lawsuits.