Boilerplate objections may be common in litigation, but they can create more problems than they solve.

In a recent article for The Texas Lawbook, Munsch Hardt Litigation Associate Jay Evans explains why young litigators should move beyond inherited discovery templates and adopt a more thoughtful approach to drafting responses under the Texas Rules of Civil Procedure.

Evans outlines five practical rules for preparing discovery responses that can withstand judicial scrutiny, including properly asserting privilege, avoiding general objections, explaining the legal or factual basis for objections and understanding when marshaling objections are appropriate.

“The template may be inherited, but the habit is yours to break.”

Read his full article here.