As a paralegal, part of your job will be to type up responses to discovery requests, including interrogatories. Sometimes, a client might have written out responses, and you will simply be typing them into the document. Other times, you will need to assist the client in formatting responses. Also, your supervising attorney may wish to “object” to certain questions. For this assignment, use the provided discovery requests from the defendant’s counsel in this employment discrimination case.
Insert our client (the Plaintiff’s), responses, which have been provided as well.
Do not change the content of the client’s responses, but be sure to clean up the language for spelling and grammatical concerns. Your work will be reviewed by your supervising attorney before it is served, but he has advised you that he wants the following objections included in the responses:
- Object to any question which requests medical information, as it is an invasion of privacy, not reasonably calculated to lead to the discovery of relevant information.
- Object to any question requesting social media information, as the requests are overbroad and irrelevant.
- Object to any questions that are unlimited in time (i.e., ask for all jobs ever held) as they are overbroad and unlimited in time.
It is your job to accurately format the objections. A set of general objections has already been placed in the beginning of the responses for you.