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Rule 2-402 Analysis

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Greetings, I hope this message finds you well. I am in receipt of your client’s answers to interrogatories and requests for production of documents. Unfortunately, upon receipt of your discovery responses, I was disappointed to learn that many of your client’s responses appear to be unresponsive, evasive, and contain improper objections. Accordingly, please accept this letter as a good faith attempt to resolve this discovery dispute.

As you know, the scope of permissible discovery as articulated in Md. Rule 2-402 is incredibly broad and permits Mr. Hamlet to discover any information that is “relevant to the subject matter involved in the action, whether it relates to the claim or defense of any other party [so long as] . . . the information sought appears reasonably calculated to lead to the discovery of admissible evidence.” Between your client’s answers to interrogatories and responses to requests for documents, you object fourteen (14) times on the grounds that the information sought is irrelevant. Md. Rule 2-402 expressly prohibits a party from unilaterally declaring that information irrelevant. Additionally, for the reasons stated below, many of the other six …show more content…
Rule 2-402 expressly states that such does not render a request objectionable. Moreover, any potential lien, and the legitimacy of such a lien, may have significant relevant to the value of this case and the legitimacy of any damages sustained by your client. As such, I fail to appreciate why this particular request is objectionable, and I would request that you withdraw your objection to the same and provide a responsive

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