How many times have you cut and paste the same template for discovery responses? Every one has general objections at the top that take up space, take time to find and replace the party names and change the gender agreement. Have you ever cited a general objection in opposing a motion to compel? How about when you bring a motion to compel? Ever asked opposing counsel to provide a further response because he or she had a general objection? I believe this is another follow the herd moment where people just do what people have done before. Unless you think they are seriously warranted in a particular case, I would cut them out.
For example, stating generally that you are not waiving the attorney/client privilege does not need to be said. I am confident the privilege is strong enough to hold up without needlessly stating it again at the beginning of each discovery document.
Another unnecessary concern is when you state something like "these are all the documents we have at this time and we reserve the right to produce more documents and will supplement these responses." First, you may have created an obligation for yourself to turn over new documents on a rolling basis. Second, of course these are all the documents you have at this time. That is all a discovery request can ask and that is all you can respond with.
Real discovery responses should have pointed objections to the actual discovery response. In my opinion, this makes your objections stronger and it looks like you took time to think about your responses. If it goes before a judge, you have clean responses that show your intent to specifically object.
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