Are "General Objections" Acceptable?

No. General Objections -- objections that precede substantive written discovery responses and purport to apply to each response -- are meaningless and they purposely obscure substantive written discovery responses.  Those serving discovery should promptly write to to the objecting party and insist that the objecting party withdraw General Objections. If the party does not do so, the propounding party should include this issue in a Motion to Compel.

This unsurprising proposition is recognized by virtually all courts nationwide.  See, e.g., Sagness v. Duplechin, No. 4:16CV3152, 2017 WL 1183988, at *2 (D. Neb. Mar. 29, 2017)[1] (“General blanket objections do not meet [the Federal Rules of Civil Procedure (“FRCP”)’s] specificity requirements and will be disregarded by this court.”); Liguria Foods, Inc. v. Griffith Labs., Inc., 320 F.R.D. 168, 187 (N.D. Iowa 2017) (rejecting general objections argument because such does not satisfy the FRCP’s “specificity” requirement); Fischer v. Forrest, Nos. 14 Civ. 1304, 14 Civ. 1307, 2017 WL 773694, at *3 (S.D.N.Y. Feb. 28, 2017) (“General objections should rarely be used . . . unless each objection applies to each document request.”); Cafaro v. Zois, No. 15-CV-80150, 2016 WL 903307, at *1 (S.D. Fla. Mar. 9, 2016) (“Boilerplate objections may also border on a frivolous response to discovery requests” (citing Steed v. EverHome Mortg. Co., 308 F. App’x 364, 371 (11th Cir. 2009))); Heller v. City of Dallas, 303 F.R.D. 466, 484 (N.D. Tex. 2014) (“Counsel should cease and desist from raising these free-standing and purportedly universally applicable ‘general objections’ in responding to discovery requests.”).  “General Objections,” as Plaintiff propounded, are not permitted under the discovery rules.  See Loudoun Cty. Asphalt, L.L.C. v. Wise Guys Contracting L.L.C., 79 Va. Cir. 605, 605 (Va. Cir. Ct. 2009).

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