Relevance: overbroad and burdensome questions

• Author: Joseph A. Ranney
• Pages: 209-222

OVERBROAD &

BURDENSOME QUESTIONS

12-1

CHAPTER 12

RELEVANCE:

Overbroad and Burdensome Questions

I. LEGAL PRINCIPLES

§12:01 What Information Is Relevant in Discovery?

§12:02 When Are Relevance Objections Permitted in Depositions?

[§§12:03-12:09 Reserved]

II. ASSERTING RELEVANCE OBJECTIONS AT A DEPOSITION

§12:10 Relevance Objection: Witness Has No Knowledge of the Facts

§12:11 Relevance Objection: Overbroad Questions

§12:12 How to Detect and Object to Overbroad Questions

§12:13 Relevance Objection: Burdensome Questions

§12:14 Request for New Documents During a Deposition

§12:15 How to State Your Position on a Relevance Objection

[§§12:16-12:19 Reserved]

III. METHODS FOR RESOLVING RELEVANCE DISPUTES

§12:20 In Camera Inspections

§12:21 Bifurcation of Discovery

IV. FORMS

Form 12-1 Letter to Counsel as to Scope of Deposition Questioning

Form 12-2 Motion for Bifurcation of Discovery

Form 12-3 Brief in Support of Motion for Bifurcation of Discovery

Form 12-4 Order Granting Motion for Bifurcation of Discovery