Boilerplate discovery responses may be dangerous in the 9th Circuit. In the case of Burlington Northern & Santa Fe Railway Company v. United States District Court for the District of Montana, 408 F.3d 1142 (9th Cir. 2005) the Ninth Circuit held that boilerplate objections for blanket refusals inserted into a response to a Rule 34 request for production of documents are insufficient to assert a privilege.
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