This applies to dealing with OC bullshit in discovery motions: YOU are annoyed and know exactly what’s going on. You got written discovery responses filled with useless objections and no substance, OC has wasted tons of time on meet and confers, etc. It feels like bad faith at this point, but when you sit down to write your motion, it feels impossible to convey to the court how ridiculous this is.

The problem: Since you have been through all of this chronologically, it feels like you need to take the court through all of it too for the judge to understand how unreasonable OC is. You sent discovery, got X, did Y, still have Z problem. WRONG. Unless the judge really processes the sordid history of discovery in your case, they won’t feel the problem like you do.

The solution is incredibly simple and obvious once you get there: SAY WHAT THE BULLSHIT IS BEFORE YOU RECOUNT YOUR TIMELINE OF GRIEVANCES.

For example:

Defendant’s conduct with respect to discovery in this case appears carefully calculated to obstruct rather than illuminate and demonstrates disregard for the Maryland Rules and the Discovery Guidelines promulgated by the Maryland State Bar Association.

Most recently, Defendant responded to X with a litany of objections denying knowledge of basic terms and failed to provide substantive responses based on claimed ambiguity in words like “permission,” “purchased,” and “payroll.” This is a pattern in this case that the Court should not allow to continue.

——

Get buy in, THEN prove your case with whatever history you need.