Today we have another example showing why Campbell, LCJ’s famous statement is as true today as when he first said it. For the text, see my blogpost “Lord Chief Justice Campbell’s Dictum,” 6/1/21.

Here’s seventeen (count ’em, seventeen) pages of Judge Morrison deconstructing the discovery objections of Jeffrey A. Miller and Patricia J. Miller, Docket No. 8820-20.*

If you need a checklist of boilerplate discovery objections, Jeff & Pat have ’em for ya. See Order at pp. 2-3. Of course, Jeff & Pat are long on objections and short on facts.

Bottom line: If you are going to object, state the facts that underpin each of your objections. Otherwise, the judge will do as Judge Morrison does, and knock them down seriatim. If you don’t have something in your possession or under your control, say so. If you promise to produce something within a time certain, produce it. Blowing a time limit and promising again, without a good explanation why you blew the time limit, doesn’t help.

Finally, if you’re going to play lawyer, learn to play it right.

*Jeffrey Miller 8820-20 9 8 21