What Obj. Goes Here (I)?
Please state how much your health insurance company has paid to cover medical treatment you received related to this accident.
What is collateral source objection
Provide any statements you have given and any statements that have been collected on your behalf.
What is (1) attorney-client privilege objection and (2) work product objection
1. Were pictures taken? If so, please produce them or state who has them.
RESPONSE: No decision has been made as to exhibits, but Plaintiff will comply with pre-trial orders. Without waiving said objection, the Plaintiff believes her brother took a picture.
Objections and responses need to be separated (with responses written with "I" statements)
this objection applies to questions about statements and investigations
What is attorney work product
the hedging phrase you should use to cover our client in case they forget something in their answers and get called out on it in trial
What is "To the best of my memory..."
Provide all details relating to any other motor vehicle accident in which you were involved from Jan. 2018 until the date of this accident.
What is relevance objection
List the names, addresses, employers, and phone numbers of each of your ex-spouses. Include in your answer the reason you are no longer married to each of them.
What is (1) relevance, and (2) overly broad [only entitled to names and maybe jobs of ex-spouses]
1. How did the accident happen?
RESPONSE: The Plaintiff states that she was stopped at a red light when the Defendant rear-ended her.
not written in the first person
This objection applies to questions about property damage settlements
What is collateral source objection [BONUS: if the property damage is low, relevance objection]
The objection that only goes without a response when our client has a felony conviction on their record
What is crimes objection
List every injury you've ever had. [besides relevance objection]
What is overly broad/not limited in scope or time objection
List every company you have ever used for health insurance.
What is (1) collateral source, and (2) not limited in scope or time
1. How did the accident happen?
RESPONSE: My duly-purchased vehicle was stopped in the northbound lane of U.S. Hwy 31 when the Defendant failed to keep a proper lookout and failed to yield the right-of-way, thereby proximately resulting in the collision.
Not in the Plaintiff's words!
This objection applies when the RFP asks for any electronic messages sent between the Plaintiff and the Defendant
equally available objection
This is why we keep the answers sweet and simple
[will accept alternative answers, but] the more details we add, the more we can be proven wrong once more evidence is collected
What body parts did you injure in this accident?
What is "not a medical expert" objection
List each witness and piece of physical evidence you intend to introduce at trial.
What is (1) witness objection and (2) exhibit objection
1. Was the Defendant drinking? State why you believe that.
RESPONSE: I know the Defendant was drinking because he was driving over 100mph and swerving before he hit me.
Too specific! Can be proven wrong.
This objection applies to questions about permanent pain
What is medical conclusion objection
Examples of these objectionable topics include health insurance benefits, disability payments, and property damage settlement checks
What is collateral source information
Produce your W-2s for the past 5 years.
What is relevance [or lost wages] objection.
What is (1) medical expert objection and (2) attorney-client privilege objection [also accepted: psychiatric privilege objection and/or spousal privilege objection]
1. Provide details of any loans on this litigation you have taken out.
OBJECTION: [collateral source, relevance]
RESPONSE: I took out a $1,000.00 loan with Oasis Financial in June 2022.
don't answer this one at all
This objection applies to questions about what the defendant did to be "negligent" or "wanton"
What is legal opinion/ultimate issue objection
Besides the MedList, name at least 1 other thing you should look for in FileVine to answer questions about amount of damages claimed
Out-of-Pocket Expenses (OOPE), Lost Wages, Diminished Value Claim (?), Add'l property damages