I have long hated boilerplate objections, which frequently are made to “kick the can” down the road. That is, if you object to a request are “unduly burdensome” or “overbroad,” you can avoid answering for now and have more time to figure out what the answer is. Or maybe your opponent will forget about the request and you will never have to answer. The flip side is use of boilerplate requests and interrogatories. I remember litigating a lease dispute case in California and wondering why I had to answer form interrogatories about an occurrence that never took place. With that a background, I enjoyed reading Steven Gensler’s new post, Is It The End Of Boilerplate In Discovery? I commend it to you.