General objections to discovery in California are not allowed. The Code of Civil Procedure requires a responding party to object separately to each interrogatory or document request and to state the specific legal ground for each objection. A blanket header at the top of a response — “Responding party objects to all requests as overbroad, burdensome, vague, and calling for privileged information” — does not comply with the statute. Courts treat that kind of boilerplate as “too general,” and a judge deciding a motion to compel can override it on that basis alone.
What the Statutes Actually Require
Two parallel provisions govern the form of an objection. For interrogatories, CCP § 2030.240 requires the responding party to “set forth clearly” the specific ground for any objection to a particular interrogatory. If privilege is the basis, the specific privilege has to be named. If work product is the basis, the claim must be “expressly asserted.”1California Legislative Information. California Code of Civil Procedure CCP 2030.240 CCP § 2031.240 imposes the same duty for document demands and adds that the response has to identify with particularity the documents falling within the demand to which the objection applies.2California Legislative Information. California Code of Civil Procedure CCP 2031.240
The response also has to be built item by item. CCP § 2030.210 directs the responding party to answer, produce writings, or object “separately to each interrogatory.”3California Legislative Information. California Code of Civil Procedure CCP 2030.210 CCP § 2031.210 requires a separate statement of compliance, inability to comply, or objection for each item or category in a document demand.4California Legislative Information. California Code of Civil Procedure CCP 2031.210 A single global objection covering thirty requests satisfies neither the specificity requirement nor the item-by-item structure.
One partial-objection rule catches people out. Under CCP § 2030.240, if only part of an interrogatory is objectionable, the rest still has to be answered.1California Legislative Information. California Code of Civil Procedure CCP 2030.240 A single problematic clause is not a license to withhold the entire response.
When an Objection Is “Too General”
The consequence of a general objection is written into the motion-to-compel statutes. A court may grant a motion to compel further responses when an objection is “without merit or too general.” That language appears in both CCP § 2030.300 for interrogatories and CCP § 2031.310 for document demands.5California Legislative Information. California Code of Civil Procedure CCP 2030.300 Boilerplate is the archetype of “too general.”
A few patterns reliably fail:
- Preamble objections that apply to every request without identifying which requests raise which problems.
- One-word tags like “Objection: overbroad” or “Objection: privileged” with no explanation of what makes the request overbroad or which privilege is being claimed.
- Burden objections that assert burden without any factual basis. To survive a motion to compel, a burden claim generally needs concrete detail — the volume of documents, the cost, the personnel hours, or the availability of cheaper alternatives. CCP § 2019.030 authorizes the court to restrict discovery that is unreasonably cumulative, duplicative, or unduly burdensome relative to the needs of the case and the amount in controversy, but the party invoking it has to show why.6California Legislative Information. California Code of Civil Procedure CCP 2019.030
- Privilege objections that name no privilege. A response saying “Objection: privileged” does not satisfy CCP § 2030.240 or § 2031.240. If the attorney-client privilege is being invoked, say so. If work product is being invoked, identify whether the material is absolute work product (an attorney’s impressions, conclusions, opinions, and legal theories, not discoverable under any circumstances) or qualified work product, which can be reached on a showing of unfair prejudice or injustice under CCP § 2018.030.7California Legislative Information. California Code of Civil Procedure CCP 2018.030
How to State an Objection That Will Hold Up
A properly stated objection addresses the specific request by number, states the legal ground, and explains why that ground applies to what is being asked. Compare two versions of the same objection:
“Objection: privileged.”
“Objection to Interrogatory No. 7 on the ground that it seeks information protected by the attorney-client privilege, as the communications described were made between Defendant and counsel for the purpose of obtaining legal advice regarding the contract at issue.”
The first is boilerplate and vulnerable to a motion to compel. The second gives the propounding party enough information to evaluate the claim and gives the court something to rule on if it comes to that.
The answer portion has to hold up too. CCP § 2030.220 requires each interrogatory answer to be “as complete and straightforward as the information reasonably available to the responding party permits.”8California Legislative Information. California Code of Civil Procedure CCP 2030.220 Evasive or incomplete responses are treated as failures to respond, which opens the door to both motions to compel and sanctions.
The 30-Day Deadline That Waives Every Objection
The bigger risk than a poorly worded objection is missing the deadline to serve any response at all. California allows 30 days after service to respond to both interrogatories and document demands.9California Legislative Information. California Code of Civil Procedure CCP 2031.260 In unlawful detainer cases, the window is five days. Miss it, and every objection is waived — including privilege and work product.
CCP § 2030.290 imposes that waiver automatically when no timely response is served to interrogatories.10California Legislative Information. California Code of Civil Procedure CCP 2030.290 CCP § 2031.300 does the same for document demands.11California Legislative Information. California Code of Civil Procedure CCP 2031.300 Relief is possible, but narrow: a court can excuse the waiver only if the late response substantially complies with the discovery rules and the failure to respond on time resulted from mistake, inadvertence, or excusable neglect. A busy caseload or a calendaring slip does not always qualify. Serve something within 30 days, even if it is a response consisting mostly of objections.
The 45-Day Deadline on the Other Side
If you are the party receiving what look like general or improper objections, the clock is running on you too. Under CCP § 2030.300 and § 2031.310, a motion to compel further responses has to be filed within 45 days of receiving the verified response.12California Legislative Information. California Code of Civil Procedure CCP 2031.310 Blow that deadline, and the right to challenge the objection is gone, no matter how boilerplate it was.
Sanctions for Unmeritorious Objections
Making general objections is not just ineffective. It is affirmatively risky. CCP § 2023.010 lists “making, without substantial justification, an unmeritorious objection to discovery” as a misuse of the discovery process.13California Legislative Information. California Code of Civil Procedure CCP 2023.010 Boilerplate objections fit that description almost by definition, because they are not tied to any particular request.
CCP § 2023.030 sets out the sanctions a court can impose:14California Legislative Information. California Code of Civil Procedure CCP 2023.030
- Monetary sanctions covering the other side’s reasonable expenses, including attorney fees.
- Issue sanctions treating certain facts as established or barring the offending party from supporting or opposing specific claims.
- Evidence sanctions prohibiting the offending party from introducing certain evidence at trial.
- Terminating sanctions striking pleadings, dismissing the action, or entering default. Reserved for egregious or repeated violations.
- Contempt sanctions.
Monetary sanctions are by far the most common outcome, and CCP § 2030.300 makes them the default. The statute says the court “shall impose” monetary sanctions against a party who unsuccessfully makes or opposes a motion to compel further interrogatory answers, unless the sanctioned party acted with substantial justification or the sanction would otherwise be unjust.5California Legislative Information. California Code of Civil Procedure CCP 2030.300 A party who fills its responses with boilerplate and then loses the motion to compel should expect to pay the other side’s costs.
The Bottom Line for Anyone Drafting Responses
California’s discovery rules leave no room for general objections. Every objection has to be tied to a specific request, state a specific legal ground, and give enough detail to let the other side and the court evaluate it. Blanket preambles get overridden as “too general.” Missed deadlines wipe out objections entirely. Boilerplate that draws a motion to compel usually draws a sanctions order with it. The extra time it takes to write a real objection to each request is small compared to the cost of losing every objection at once.