The rest of the response says that defendant cannot respond because it has not yet selected experts.
Rule 2-402(g), that rule does not address the production of materials provided to expert witnesses. Rule 2-402(f) governs the production of statements given by parties or witnesses, not the scope of expert discovery. 7 on the basis that “it exceeds the scope of expert discovery under Rule 2-402(f).” Md. Now that defendant has named experts, please provide a response to this request. Rule 2-402(g), which does address expert discovery, you are still wrong because the law requires the production of “any written report made by the expert” concerning the expert’s findings and opinions. 6 on the basis that “it exceeds the scope of expert discovery under Rule 2-402(f).” Md. Are there any documents like these? If there are, which ones do you contend are proprietary and confidential and why? You must at least tell me if any responsive materials exist, so that I may seek the assistance of the Court in resolving your objection. You have not indicated whether any materials like this exist. 4 on the basis that it is “vague, overly broad and unduly burdensome,” and that “it seeks information that is proprietary and confidential.” Surely you understand what material is sought by this request, otherwise, how could you determine that it “seeks information that is proprietary and confidential?” This request is directed at discovering documents or other materials relevant to the defendant’s policies and training regarding floor care, inspection and maintenance, such as guidelines showing how often floors are inspected, and what employees are supposed to do in the event of a hazard.
The way you have made these general objections makes it impossible for me to tell which requests you think these objections apply to or why you think they are objectionable and I do not believe the Rules require me to guess. If you believe that any of these individual requests are objectionable, please make your objections as required by the rule. Rule 2-422(c) requires that the grounds for any refusal to produce must be fully stated in response to each specific request. I'd like to lay our my concerns in hopes that you will modify your answers without the need to involve the court.įirst, you include eight “general objections.” One big problem I have with these: the Maryland Rules do not permit general objections. This appears to be an exercise in legal gamesmanship rather than the real, good faith effort to provide discovery that is contemplated by the Maryland Rules. Eleven of the seventeen responses I have received are subject to some sort of objection. I do not believe that the responses I have received represent a good faith effort to provide discovery. These raise several issues that I must bring to your attention. I have had an opportunity to review Defendant’s Responses to Requests for Production.
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