Junior lawyers (5 years or less experience) may have multiple attorneys argue if notified in advance.

Conclusory objections to discovery requests are prohibited; must explain specific grounds.

Must seek clarification before objecting to vague discovery requests.

Must produce discovery within undisputed scope when objecting to overly broad requests.

Objecting then answering "notwithstanding" is prohibited as it preserves nothing.

Objections must state whether responsive materials are being withheld.

Privilege objections must identify specific nature, subject matter, sender, receiver, and relationship.

Privilege objections without proper privilege log may be deemed waived.

Nonprivileged materials must be produced without delay while preparing privilege log.

Party asserting privilege must present sworn evidence to support claim if necessary.