Danielle S. asked
In a federal FCRA civil case, I answered the defendant's 23 interrogatories with answers 14 times and objections for the others. The attorney responded by telling me that my objections were improper and that if I didn't change them he was filing a Motion to Compel (MTC) the next day asking for sanctions and costs. I researched what he said and revised my answers by responding with an allowed objection, and "Subject to and without waiving" and answered all but two of them. Now he's writing me that "Subject to" means I'm hiding something and unless I answer with “without waiving the objection” instead he's filing the Motion to Dismiss (MTD) tomorrow. They are demanding my SSN, and I'm objecting. (privileged and confidential, protected, etc.) and he says since this is an FCRA case I have to provide it. 1) Is he correct re: Subject to? 2) how likely is the court to sanction me and make me pay for costs? 3) is he correct re: SSN?
May 14th, 2024
Robert J. answered
1) The use of "Subject to" in your objections is perfectly fine and does not imply that you are hidi...
May 14th, 2024
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