Discovery Hell

I am a youngish associate. At my firm, that means you get all the court appearances (score!) and draft all the discovery responses (ugh).

Last week I was in discovery hell. I had 16 sets of discovery to which I had to respond. While I typically don't mind responding to discovery, these sets were particularly bad. You see, for the past several months I've been branching off and taking on cases in fields of law other than my norm. For some reason or another, the Plaintiffs' attorneys in these types of cases are absolute morons. They ask questions that just beg for me to object.

Here is a prime example:
"List all documents that support any and all of your affirmative defenses."
My dream response?:
"Objection. You're a moron. I can't believe someone actually gave you a law degree, and worse yet, I can't believe you passed the same bar as reputable attorneys in this state. Further objection is made on the grounds that your grammar and logic are completely absent from this discovery request. Without waiving the foregoing objections, Responding Party replies: the Magna Carta, the Declaration of Independence, the Constitution, all case law in the history of the United States and England...."

I mean seriously, could the attorney not draft a better request?

What was I supposed to do?

I finally gave up making fun of him (except for in this blog) and just helped him as the question he couldn't ask:
"Objection. This request is overbroad, unduly burdensome, vague and ambiguous, seeks privileged information, seeks information not reasonably calculated to lead to the discovery of admissible evidence, is improper in that it violates Court Rule 3.12, the term "you" is not defined. Without waiving the foregoing objections, Responding Party replies: Without further clarification Responding Party is unable to fully respond, however, assuming Requesting Party was requesting all relevant factual documents supporting Responding Party's affirmative defenses that are in Responding Party's possession, Responding Party replies: Contract dated September 2, 1999; Confirmation Bates Stamped BA0002398, etc...."

Ok, I am typing this post and am not publishing my exact words (hopefully Plaintiff's counsel doesn't stumble on this post and put two and two together), but you get the point.

By the end of the week, and after having spent most of the week responding to such nonsense, I looked a little like a crazed teddy bear.