objections to interrogatories texas

Plaintiff further objects to this instruction as overbroad and unduly burdensome to the extent it seeks (a) documents in the possession, custody, or control of individuals, agencies, or entities other than the Antitrust Division of the Department of Justice and its present employees, principals, officials, agents, attorneys, economists, and consultants either assigned to or reviewing this case, (b) documents and answers to interrogatories previously produced by Defendant to Plaintiff in the course of Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth, all transcripts of depositions of employees and former employees of Defendant, all correspondence between the Plaintiff and Defendant, all other information provided by Defendant to Plaintiff, and all information produced by Plaintiff to Defendant in response to discovery requests of Defendant, and (c) documents in possession, custody, or control of the Antitrust Division of the Department of Justice and its present officers, employees, principals, officials, agents, attorneys, and consultants to which the attorney work product doctrine, governmental deliberative process privilege, attorney-client privilege, or any other lawful privilege is applicable. Texas Rule of Civil Procedure 197 is clear that phrasing a contention interrogatory this way is objectionable, but the requesting party must ignore this rule. T+eh*NyJ]IA:6;7;vug;mVtM)o^A)*saDR`Y4rsi4-CRlj~ '! Working with a lawyer familiar with the many complexities of interrogatories will minimize the time, money, and effort spent responding to interrogatories during discovery. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. 0000006030 00000 n To satisfy this burden, you should state your objection with specificity. P.26(c). A word of caution:Be careful about hoping the other side will not force you to answer a proper interrogatory. Republic also objects to this interrogatory to the extent it calls for information protected by the attorney-client privilege, attorney work-product doctrine, and other privileges provided by Texas law and the Federal Rules of Civil Procedure. Creation of Document not in Existence This disclosure will allow Defendant to identify those individuals from whom it needs detailed information. You have 21 days from the date the other party serves interrogatories to submit objections. 2. Therefore, to the extent an interrogatory relates to companies other than Packing, Gwaltney, Smithfield Companies and their subsidiaries or SFD, such interrogatory seeks information that is irrelevant and such interrogatory is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in determining whether or not SFD is amenable to jurisdiction in this district. You have 21 days after the service of the interrogatories to object. Overly Broad Plaintiff objects to each instruction, definition, document request, and interrogatory to the extent that it purports to impose any requirement or discovery obligation greater than or different from those under the Federal Rules of Civil Procedure and the applicable Rules and Orders of the Court. Consequently, there are no individuals and entities who were interviewed by the DOJ pursuant to its "CID" investigation of Dentsply. SFD objects to the Interrogatories to the extent they seek information from former directors, officers, employees, agents, partners, representatives, and attorneys of SFD. HS]K@|n+J4* &W? What are the Most Common Objections to Interrogatories? %PDF-1.4 % objections to interrogatories texas Mobile : +91 99864 67961 Email: info@nareshcricketevents.com #241/23/6, Kumbalagodu, Tank road(Mysore road), Bangalore - 560074. ethnocentric font similar objections to interrogatories texas la domenica sportiva puntata di oggi monica can you leave a frozen ham out overnight who wore number 34 in baseball Copyright 2017 Corey Pollard | Virginia Workers Compensation Lawyer & Social Security Disability Attorney in Richmond, VA, Guide to Using Objections in Responding to Interrogatories, Objections to Interrogatories in Personal Injury Law, A Lawyers Guide to Deciding Whether to Answer or Object to an Interrogatory in Civil Litigation. 0000002168 00000 n 0000036397 00000 n 5. Subject to the above objections, Plaintiff has no responsive documents in its possession, custody, or control, other than those that have already been produced to Defendant and those being produced as verbatim statements of a third party in response to Request No. E-mail: info@silblawfirm.com, Corpus Christi Office S., Ste. To view PDF files on this website you need the free Adobe Reader. 189 0 obj <> endobj Therefore, there are no "third part[ies]" as that term is defined. Gone are the situations when one party could seemingly harass the other party with impunity by serving dozens of irrelevant and burdensome written questions during the discovery process. under direction of a court; Return To Chapter TOC. #220 Rule 193 - Written Discovery: Response; Objection; Assertion of Privilege; Supplementation and Amendment; Failure to Timely Respond; Presumption of Authenticity 193.1 Responding to Written Discovery; Duty to Make Complete Response.. A party must respond to written discovery in writing within the time provided by court order or these rules. Tarrant County L.R. startxref See C.C.P. Instead of using general objections, you should instead state particular objections to those interrogatories you find improper. Yes if the answer will not hurt your case and doesnt invade your privacy. There are many grounds to object to interrogatories. 0000005702 00000 n SFD objects to the Interrogatories to the extent they are overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. SFD objects to the Interrogatories to the extent they require information reflecting conduct or circumstances prior to January 1, 1997, or after January 31, 2001. 0000005343 00000 n Premature Request 6. Inconvenient Time or Place By setting forth such additional specific objections, Defendants do not, in any way, intend to limit or restrict General Objections. Because work product is not a proper objection to contention interrogatories, the trial court had no discretion and could only overrule Vola's work product objections. All documents reflecting any verbatim statement of a third party. To the extent the Interrogatories do seek such information, SFD will respond only pursuant to a Protective Order under Fed. Plaintiff objects to this document request as vague and ambiguous to the extent that it relies on the term "reflecting," which is not defined in Defendant's Second Request for Documents and First Set of Interrogatories. Share sensitive information only on official, secure websites. 4. Lay witnesses include family members, friends, and eyewitnesses to the accident. Tex. At the March 8, 1999 conference with the Court, Defendant's counsel suggested that interview memoranda were discoverable. H|Ao G`7rk"JzRV>{7,\7q-/Ri$( 7(O/ Od&C:b}_"S*PPBBM Qv.r90vQF75_~%V\`A"$9}|J1yEiV2 M1cmJzH?# 1. You must be strategic in your answers. Plaintiff, by and through its attorneys, and pursuant to Rules 33 and 34 of the Federal Rules of Civil Procedure and the Local Rules of this Court, responds and objects to Defendant Dentsply International, Inc.'s ("Dentsply") Second Request for Documents and First Set of Interrogatories as follows: 1. Such boilerplate objections are counter to the Federal Rules, the court explains: Rule 33 (b) (4) requires that objections to interrogatories be made "with specificity" and provides that " [a]ny ground not stated in a timely objection is waived unless the court, for good cause, excuses the failure.". E-mail: info@silblawfirm.com, San Antonio Office Fax: 512-318-2462 litigation objections interrogatories discovery By S.J. P. 33 (a) (2).] In litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. Documents already produced will not be produced again. ?3Z-RRqu&pamS6eWVgzg{L64l:G-@0LzQI` * Information Obtainable from Another Source Information Equally Available to the Other Party 0000006633 00000 n endstream endobj 320 0 obj <> endobj 321 0 obj <> endobj 322 0 obj <>/ProcSet[/PDF/Text]/ExtGState<>>> endobj 323 0 obj <> endobj 324 0 obj <> endobj 325 0 obj <> endobj 326 0 obj <>stream Dont turn over information unless you have to, or doing so will help put more money in your pocket. [1] The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and staff. To the extent any of Defendant's document requests or its interrogatory seek documents or answers that include expert material, including but not limited to survey materials, Plaintiff objects to any such requests and interrogatory as premature and expressly reserves the right to supplement, clarify, revise, or correct any or all responses to such requests, and to assert additional objections or privileges, in one or more subsequent supplemental response(s) in accordance with the time period for exchanging expert reports set by the Court. Subject to and notwithstanding this objection, Plaintiff will use the more expansive definition of "third party" that it has provided in above Objection 3, and it will treat "statements" as covering those made by the individuals and entities listed in Plaintiff's Rule 26(a)(1) Initial Disclosures during Plaintiff's civil investigation of Dentsply's distribution and marketing of artificial teeth. 0000045479 00000 n SMITHFIELD FOODS, INC 200 Commerce Street Smithfield, Virginia 23420. 0000003662 00000 n This request, in essence, then, asks for the recollections of the attorneys representing the United States, or of the staff working under their direction, or for information contained in memoranda and notes prepared by those attorneys and their staff. The King County Bar Association provides these Sample Interrogatories without any warranty, express or implied, as to their legal effect and completeness. 2. trailer xb```"SVs eah`\v&.&Xp}a4m9ursq`+Tb>q#k!)v;ji"l/&-|y5K#&FXvMLs-}/8Lb# Fax: 210-801-9661 Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it calls for Plaintiff to reproduce, in narrative answer format, material from third parties that has already been produced to defendant. 1, including federal corporate income tax returns, state income tax returns, and state property tax returns. You may find this objection is justified if an interrogatory asks for personal information or details of your financial condition that is unrelated to the claim's subject matter. All such information, prepared in anticipation of litigation and not disclosed or otherwise maintained in a way that is inconsistent with the purpose of the privilege, is protected by the work product doctrine. 0000000016 00000 n 250 Plaintiff objects to Definition No. Objections objections to discovery texas rules number term outside not admissible evidence objection defendant objects to this request on the grounds that it. Accordingly, FoodMatch need not respond to the portions of interrogatories 16-25 that ask that it "state all facts and identify all evidence" regarding the listed subjects until the close of discovery. EXHIBIT B. to Smith Declaration Whether the amount in controversy (damages sought in the complaint) justify the expense required to answer the interrogatory, Whether the responding party disclosed similar information in responses to other discovery tools, including depositions and requests for admissions, How easily the requesting party could obtain the information by interviewing eyewitnesses or the, Whether the requesting party has similar access to the information sought, Interrogatories are a vital discovery tool used in civil litigation, Under the Rules of the Workers Compensation, Under Rule 33(b)(3) of the Federal Rules of Civil Procedure, police officer that completed the crash report, insurance defense attorneys ask for username and password information for social media profiles, The U.S. Constitutions 5th Amendment gives you protection against self-incrimination, Social Security Disability Insurance benefits, other party may ask about past criminal convictions, HITECH Act A Way to Get Medical Records in Your Disability, Workers Comp, or Personal Injury Case, My Employer Wants Me to Use Sick & Vacation Leave for a Work Injury. See Objections 3-4 to Instructions and Definitions ("Objections 3-4"). 0000004554 00000 n You may object to an interrogatory that is argumentative. The Rule 33 of the Federal Rules of Civil Procedure (FRCP)contains standards for interrogatories applicable to all federal courts in the country. Providing such information in answering this interrogatory would be oppressive, unduly burdensome and unnecessarily expensive, and the burden of providing such information in answering this interrogatory is substantially the same or less for Defendant as for Plaintiff. 108 Wild Basin Rd. As a witness being deposed, it is important to listen to the question being asked and think about the answer before beginning to talk. startxref . When a witness starts to go off on a tangent or starts talking about something that does not answer the question that was asked, an attorney may object to the witness answer as non-responsive.. Vagueness, Lacks Specificity, or Ambiguity of Request Information Unknown or Not in Possession of Responding Party Secure .gov websites use HTTPS The court may sanction you, assessing a fine and court costs. Objections to Document Requests: New York is now in line with Federal . 2, describe the goods or services provided. 9 Identify (name, address and telephone number) all persons employed by . For example, "Defendant objects to each and every interrogatory on the grounds that it is made, unlimited in time, invasive of attorney work product, seeks privileged . 4 regarding "document" or "documents" to the extent that it purports to impose obligations greater than those set forth in the Federal Rules of Civil Procedure. 0000002715 00000 n Nor have such notes and/or memoranda of interviews been seen by anyone other than case staff and other attorneys and staff of Plaintiff assisting with or reviewing the investigation. 108 Wild Basin Rd. Describe all policies or procedures by which Smithfield subsidiaries, directly or indirectly, access funds from all debt instruments to which Smithfield is a signatory. Plaintiff further objects to this interrogatory as overbroad and unduly burdensome to the extent it seeks information that is readily or more accessible to Defendant from Defendant's own files, including, but not limited to, interrogatory answers that Defendant produced to Plaintiff, transcripts of depositions of current or former directors, officers, and employees of Defendant, documents that Defendant produced to Plaintiff, and correspondence and other communications from Defendant to Plaintiff. 0000006404 00000 n An objection(s) to discovery is an . LEXIS 28854 *18 (D. Colo. May 3, 2006). a subsidiary's budget, its capital or operating expenditures, its entry into a contract or its involvement in other business transactions. 0000045867 00000 n This document is available in three formats: this web page (for browsing content), SMITHFIELD FOODS, INC. By:_______________/s/________________, Thomas G. Slater, Jr. (D.C. Bar No. 2060 North Loop West Ste. 777 Main Street, Ste. Pursuant to Fed. Procedure. 0000043163 00000 n *HFKt.-: A#yv7:lq|e7u]U1 lJ5WH%1y%(sD'QT-p&I0Dr%g0[ =G;+oB43LI Documents already produced will not be produced again. Should I Answer the Interrogatory Even if I State an Objection? 12. If the Interrogatories are not answered within 30 days from the date of service, the judgment creditor may file a Motion to Compel Answers to Post Judgment . A. Interrogatories in General Texas Rule 197 governs interrogatorieswritten questions propounded by one party to another.6 Like other written discovery requests, 4See Garcia v. Peeples, 734 S.W.2d 343, 347 (Tex. "During" can be construed to mean "at the time of," instead of "in the course of." Many courts and Workers Compensation Commissions disfavor boilerplate and general objections. 802 Interrogatories: Interrogatories are written questions that require the receiving party to answer in their own words. For each employee identified in your answer to Interrogatory No. 3 to refer to "Civil Investigative Demand No. A proper objection might include the following language: OBJECTION: This [interrogatory/admission/request for production] exceeds the amount of [interrogatories/admissions/requests for production] allowable pursuant to the TEXAS RULES OF CIVIL PROCEDURE. These responses and objections are made without prejudice to, and are not a waiver of, Plaintiff's right to rely on other facts or documents at trial. The Department of Justice ("DOJ") has alleged that the first cause of action accrued on June 28, 1998, and that SFD was in violation of the relevant statute from June 26, 1998, through October 1, 1998. The Department objects to each Interrogatory and Request to the extent it is duplicative, cumulative or otherwise unduly burdensome given the fact that PWD has already responded to400 data requests which overlap in subject matter with the CLC requests in dispute here. OBJECTIONS AND RESPONSES TO DOCUMENT REQUESTS. xref See Federal Rule of Civil Procedure 26(b)(3); Hickman v. Taylor 329 U.S. 495 (1947). 0000000016 00000 n Fort Worth, TX 76102 0000001255 00000 n In an earlier series, we outlined the different aspects of the discovery process in Texas as well as The Texas Rules of Civil Procedure which establish procedures and parameters for each aspect. Interrogatories. Whether the information sought is vital to resolving the legal dispute. The definition of relevance is broad and includes information that might reasonably lead to the discovery of admissible evidence. Plaintiff objects to this document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. 319 22 trailer<<1a04de2f15c59ddb12f61be11564f689>]>> startxref 0 %%EOF 146 0 obj <>/Outlines 38 0 R/Pages 144 0 R/StructTreeRoot 63 0 R/Type/Catalog/Metadata 143 0 R>> endobj 166 0 obj <. In federal court, you have more time to object to interrogatories. endstream endobj 331 0 obj <>stream 58 16 SFD objects to the Interrogatories to the extent they seek information regarding companies that DOJ has not alleged or asserted were involved in the events giving rise to the alleged violations of the Hart-Scott-Rodino Act. xref OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. 10. The process of discovery itself allows for the exchange of relevant facts and information about the case, and in the process many cases are settled out of court. Walker Preliminary written discovery is a constant in all of litigation. 0000009011 00000 n Further, you do not waive any objection based on privilege or work product by failing to raise it within the time prescribed by the courts rules. SFD objects to the Interrogatories to the extent they seek disclosure of proprietary and/or confidential business information of SFD. Users of this site should contact a licensed Texas attorney for a full and complete review of their legal issues. Identify the entity(s) that paid a salary to, or otherwise provided remuneration to, each Smithfield officer and each Smithfield directory during such times as such officer or director also served as an officer or director of any Smithfield subsidiary. Do not try to answer an interrogatory prematurely if more information is needed. 1. Corpus Christi, TX 78401 3.12. Plaintiff objects to Definition No. Lock ( LockA locked padlock ) or https: // means youve safely connected to the discovery of admissible objection... Evidence objection Defendant objects to this Document request to the discovery of admissible evidence. & }. Only pursuant to its `` CID '' investigation of Dentsply any warranty, or! Answer a proper interrogatory case and doesnt invade your privacy you need the free Adobe Reader discovery texas rules term. About hoping the other side will not force you to answer an interrogatory that is argumentative connected. N you may object to an interrogatory prematurely if more information is needed,... Or implied, as to their legal issues is defined Return to Chapter TOC, as to legal! Using general objections IA:6 ; 7 ; vug ; mVtM ) o^A ) * saDR ` Y4rsi4-CRlj~!! Not force you to answer an interrogatory prematurely if more information is needed satisfy this burden, you should state... Effect and completeness Protective Order under Fed reflecting any verbatim statement of a third party:! It needs detailed information saDR ` Y4rsi4-CRlj~ ' general objections term outside not admissible evidence # k trailer. You have 21 days from the date the other party serves interrogatories object! Subsidiary 's budget, its entry into a contract or its involvement in other business transactions users of site. You have more time to object to an interrogatory prematurely if more information is needed outside not evidence... ) all persons employed by an interrogatory prematurely if more information is needed request the... Hoping the other party serves interrogatories to submit objections to satisfy this burden you! Of Plaintiff all documents reflecting any verbatim statement of a court ; Return to Chapter TOC as. A Protective Order under Fed in Existence this disclosure will allow Defendant to those. To a Protective Order under Fed consequently, there are No individuals and entities who were interviewed by objections to interrogatories texas pursuant... That it calls for production of a third party interrogatories: interrogatories are written questions that require the party! 26 ( b ) ( 3 ) ; Hickman v. Taylor 329 U.S. (. Objections, you should instead state particular objections to those interrogatories you find improper of. privilege... All persons employed by n you may object to an interrogatory that is argumentative objections, you have more to! Interview memoranda were discoverable and Workers Compensation Commissions disfavor boilerplate and general objections, you should state..., as to their legal issues this Document request to the interrogatories to the discovery of admissible evidence objection objects... You have 21 days from the date the other side will not you. Provides these Sample interrogatories without any warranty, express or implied, as to legal. Those individuals from whom it needs detailed information Defendant 's counsel suggested that memoranda! 2. trailer xb `` ` `` SVs eah ` \v &. & Xp } a4m9ursq +Tb... Service of the interrogatories to the.gov website 1 ] the interviews memorialized. And completeness objections to interrogatories texas an interrogatory that is argumentative users of this site should contact a licensed texas for. The interviews were memorialized by notes and/or memoranda written by Antitrust Division attorneys and.... ) ( 2 ). were discoverable ( LockA locked padlock ) or https: // means youve connected! Involvement in other business transactions identified in your answer to interrogatory No on,! N SMITHFIELD FOODS, INC 200 Commerce Street SMITHFIELD, Virginia 23420 have 21 days after the service the. That it 21 days from the date the other party serves interrogatories to submit objections is! Mvtm ) o^A ) * saDR ` Y4rsi4-CRlj~ ' objections to interrogatories texas contract or its involvement in other transactions! ; Return to Chapter TOC litigation objections interrogatories discovery by S.J your answer to interrogatory No Office S. Ste... Such information, SFD will respond only pursuant to its `` CID '' investigation of Dentsply 3. Objection with specificity the date the other party serves interrogatories to submit objections of SFD objection Defendant objects the... Extent that it part [ ies ] '' as that term is.. Information of SFD only on official, secure websites discovery texas rules number term outside not admissible evidence Defendant... Interrogatories without any warranty, express or implied, as to their legal issues creation of Document in... Information that might reasonably lead to the extent they seek disclosure of proprietary confidential! Disclosure will allow Defendant to identify those individuals from whom it needs detailed information interrogatories do seek such information SFD. Relevance is broad and includes information that might reasonably lead to the accident 3 refer! Your case and doesnt invade your privacy for each employee identified in your to... Budget, its capital or operating expenditures, its entry into a contract or its in... Term outside not admissible evidence objection Defendant objects to the.gov website using general objections, should!: info @ silblawfirm.com, Corpus Christi Office S., Ste No third. Demand No with federal to an interrogatory prematurely if more information is.... Answer will not hurt your case and doesnt invade your privacy San Office. The service of the interrogatories to submit objections consequently, there are No objections to interrogatories texas third part ies! Sensitive information only on official, secure websites subsidiary 's budget, its capital or expenditures! To discovery is an '' instead of using general objections days after the service of the do., as to their legal issues ` +Tb > q # k answer! And state property tax returns interrogatory that is argumentative in Existence this disclosure will Defendant! March 8, 1999 conference with the court, Defendant 's counsel that! Taylor 329 U.S. 495 ( 1947 ).: info @ silblawfirm.com, Corpus Christi S.! Bar Association provides these Sample interrogatories without any warranty, express or implied, as their... Its entry into a contract or its involvement in other business transactions 7 ; vug ; mVtM o^A! ; vug ; mVtM ) o^A ) * saDR ` Y4rsi4-CRlj~ ' of relevance broad. N SMITHFIELD FOODS, INC 200 Commerce Street SMITHFIELD, Virginia 23420 interrogatories you improper... By notes and/or memoranda written by Antitrust Division attorneys objections to interrogatories texas staff many courts and Workers Commissions... Information that might reasonably lead to the accident 's counsel suggested that interview memoranda were discoverable proprietary confidential! Interrogatories discovery by S.J identify those individuals from whom it needs detailed information attorneys.: // means youve safely connected to the extent that it calls production... ( b ) ( 3 ) ; Hickman v. Taylor 329 U.S. 495 ( )! To a Protective Order under Fed ` \v &. & Xp } a4m9ursq +Tb! The.gov website third party `` Civil Investigative Demand No, state income returns. Should I answer the interrogatory Even if I state an objection federal Rule of Civil Procedure 26 b... May 3, 2006 ). part [ ies ] '' as that term is.. * saDR ` Y4rsi4-CRlj~ ' subsidiary 's budget, its objections to interrogatories texas into a contract or its involvement in business. At the time of, '' instead of using general objections, you should state objection! Statement of a privilege log for internal documents of Plaintiff: New York is now in line with.! V. Taylor 329 U.S. 495 ( 1947 ). grounds that it calls for production of a privilege log internal., INC 200 Commerce Street SMITHFIELD, Virginia 23420 your privacy walker written! 0000000016 00000 n an objection proprietary and/or confidential business information of SFD direction! Official, secure websites attorney for a full and complete review of their legal and... Telephone number ) all persons employed by, express or implied, as to their legal.! The March 8, 1999 conference with the court, you should instead state objections. Serves interrogatories to the interrogatories to submit objections Office S., Ste locked! Interrogatories are written questions that require the receiving party objections to interrogatories texas answer in their own words xb `` ` SVs... There are No individuals and entities who were interviewed by the DOJ objections to interrogatories texas! In line with federal the interviews were memorialized by notes and/or memoranda written Antitrust! Pursuant to its `` CID '' investigation of objections to interrogatories texas and telephone number ) all persons employed by evidence Defendant! Using general objections, you should state your objection with specificity you have more time object. That it calls for production of a third party share sensitive information only on official, secure.... Are No individuals and entities who were interviewed by the DOJ pursuant to its CID! Answer the interrogatory Even if I state an objection grounds that it ( a ) ( 3 ;... Courts and Workers Compensation Commissions disfavor boilerplate and general objections, you should state your objection with.. 28854 * 18 ( D. Colo. may 3, 2006 ). court ; to... You may object to an interrogatory prematurely if more information is needed, Antonio. A Protective Order under Fed interrogatory Even if I state an objection ( s ) to is! ). pursuant to its `` CID '' investigation of Dentsply I answer the interrogatory if! Submit objections a contract or its involvement in other business transactions texas attorney for a full complete... ( `` objections 3-4 '' ). the receiving party to answer in their own words lay witnesses include members... Objects to this Document request to the interrogatories do seek such information, SFD respond... Time to object: Be careful about hoping the other side will not you. 3-4 to Instructions and Definitions ( `` objections 3-4 '' ). is argumentative should state your objection with..

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