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Rule 37(a)(3), SCRCP explicitly states an evasive or incomplete answer [to discovery] is to be treated as a failure to answer. Parties and attorneys issuing evasive discovery responses may think they are being clever but they are actually limiting their input on contested issues at trial.Feb 9, 2016. : a formal question or inquiry especially : a written question required to be answered under direction of a court. (Rule 26(b)(5)(A).) In the event that an extension of discovery deadlines is necessary, we recommend seeking consent from opposing counsel and/or relief from the court . All other objections, say for relevance, for hearsay, and even for harassment, cannot justify an instruction to the witness to refuse to answer. (NRCP 33; JCRCP 33) Create a clear record that the witness is abiding by counsels instruction, refusing to answer the questions posed. Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031.280, 2023.050, and 2016.090. . In other words, your answers, even if prepared by your attorney, must include a notary publics signature and seal. If the party was served by mail, the deadline for any response to the document is extended by 5 days . 32. The specific code section depends upon the type of written discovery. The matters stated in the foregoing document are true of my own knowledge, except as to those matters which are stated on information and belief, and as to those matters, I believe them to . 2 How to Compel Responses or Further Responses to Interrogatories Unless this agreement expressly states otherwise, it is effective to preserve to the responding party the right to respond to any item or category of item in the demand to which the agreement applies in any manner specified in Sections 2031.210, 2031.220, 2031.230, 2031.240, and 2031.280.