Civil Procedure – Discovery – General Objections

A Loudoun County Circuit Court grants defendant contractor’s motion to compel discovery responses from plaintiff asphalt company, which has only filed general objections to the discovery requests.

I agree with defendant’s argument that the general objections of plaintiff to the subject discovery requests are confusing and not related to any particular discovery request. I am unable to tell which of the many general objections apply to which discovery request. At the very least I think such general objections are not permitted under the discovery rules unless a party in good faith makes it clear that every general objection applies to every discovery request. Considering the issues raised by the pleadings and the discovery in this case, I do not see how plaintiff in good faith can assert every general objection to every discovery request.

Plaintiff asserts it is not required to produce certain documents because of confidentiality, privilege or work product, yet it provided no privilege log or logs as required by Rule 4:1(b)(6). If plaintiff asserts confidentiality, privilege or work product in its future responses to discovery, then it must provide a privilege log describing the documents not produced as required by the discovery rules.

Loudoun County Asphalt LLC v. Wise Guys Contracting LLC (Chamblin, J.) No. 52193, Loudoun County Cir.Ct.; James R. Hart, Shoshana E. Rothman, Ralph D. Rinaldi for the parties. VLW 009-8-259, 2 pp.