Wednesday, April 23, 2014

Got This from Opposing Counsel Today

So, I got this interrogatory from an opposing counsel today:
22. State the name and address of all persons who have been present in the presence of [client's child] and state the dates thereof.
The child in question is three years old.

Hmmmmm.... List every person who has ever been in the presence of your child, ever? Oh, and the dates, too, if you don't mind. Ok...

So here's my question: I know the OB/GYN who delivered the child three years ago would be first on the list. That's obvious.

After that, you've definitely got all the other babies in the hospital nursery, the nurses, the family members, and so on. After that, you've maybe got all the children in daycare, all the teachers, and those children's parents. That's not too hard. After that what else?

I mean, there's kids at birthday parties, but hopefully that overlaps with the daycare friends. I'm informed and believes that on Christmas Eve, a certain St. Nick came to visit the child, but how detailed to we go here? There are people in parks, church, and good luck answering if the child has ever traveled via mass transit.

Anyone have any ideas?

Right now, my draft answer is an objection on the grounds of not being omniscient. But that's a cop-out, right?


  1. See if you can enter the local telephone book into evidence. An absurd question deserves an absurd answer.

  2. I like that, but it's possible that even the local telephone book wouldn't have everyone in it. What about people who don't live in the local area?

  3. Perhaps you could add "and any other person residing or visiting or traveling within 10 miles of any of the addresses". To further highlight the absurdity, include calendars.

  4. Hmmmmm........ Copy of the last census conducted in SC?