§ 193.2. Objecting to Written Discovery
193.2. Objecting to Written Discovery
(a) Form and Time for Objections. A party must make any objection to written discovery in writing--either in the response or in a separate document--within the time for response. The party must state specifically the legal or factual basis for the objection and the extent to which the party is refusing to comply with the request.
(b) Duty to Respond When Partially Objecting; Objection to Time or Place of Production. A party must comply with as much of the request to which the party has made no objection unless it is unreasonable under the circumstances to do so before obtaining a ruling on the objection. If the responding party objects to the requested time or place of production, the responding party must state a reasonable time and place for complying with the request and must comply at that time and place without further request or order.
(c) Good Faith Basis for Objection. A party may object to written discovery only if a good faith factual and legal basis for the objection exists at the time the objection is made.
(d) Amendment. An objection or response to written discovery may be amended or supplemented to state an objection or basis that, at the time the objection or response initially was made, either was inapplicable or was unknown after reasonable inquiry.
(e) Waiver of Objection. An objection that is not made within the time required, or that is obscured by numerous unfounded objections, is waived unless the court excuses the waiver for good cause shown.
(f) No Objection to Preserve Privilege. A party should not object to a request for written discovery on the grounds that it calls for production of material or information that is privileged but should instead comply with Rule 193.3. A party who objects to production of privileged material or information does not waive the privilege but must comply with Rule 193.3 when the error is pointed out.