What if you ask for sanctions with the motion to compel, and after doing so, the discovery is finally sent? Can you still go forward with the sanctions? If so, how likely are you to receive the reimbursement of cost to file the motion to compel with the request for sanctions?
Hi Terri. You can still go forward with the request for sanctions, however that request is unlikely to be granted unless the violation is very egregious (for example, the judge specifically told the opposing party multiple times that they have to produce discovery by a certain date, and despite that warning they failed to provide the documents by that date).
Hi! I appreciate and enjoy your videos. What would be an appropriate objection to a request to sign an authorization to "furnish opposing counsel with any and all information, documentation or opinions they request regarding any and all documentation and information sought that he may have in his possession and/or control in connection therewith." It seems exceedingly vague and invasive. Thank you!
Hi Tricia. That is quite the request. I've never heard of such a thing. I would object based on the following: "The Plaintiff/Defendant objects to this request on the grounds that it is vague, overly broad as to time and scope, unduly burdensome and oppressive, not reasonably calculated to lead to the discovery of admissible evidence, intended to harass, requests documents not within the Plaintiff/Defendant’s access or control, and requests documents within the Plaintiff/Defendant’s access and control."
