“I Will Supplement Later” Does Not Answer an Interrogatory.

Succinctly stated:

In response to Plaintiff’s Motion [to Compel], Defendant advised the Court that documents describing the coverage determination would be produced in the future….  “[S]tating one will ‘supplement’ at a later date does not amount to an initial response to a request for information but rather, is an attempt to subvert the requirements of the discovery rules.”

EPT Montecillo Town Ctr. Apts., LLC v. Zurich Amer. Ins. Co., 2026 WL 194901 (W.D. Tx. Jan. 16, 2026).

To avoid an obligation to respond or produce, a party resisting discovery must raise a valid objection to each challenged request. An objection to an interrogatory is waived, and thus invalid, unless the grounds for the objection are “stated with specificity.” Fed. R. Civ. P. 33(b)(4). Similarly, a response to a request for production “must either state that inspection and related activities will be permitted as requested or state an objection to the request, including the reasons.” Id. at 34(b)(2)(B).

Id. at *1.

The court wrote that: “An interrogatory need not be the best form of discovery – it simply must be a permissible form of discovery.” Id. at *3 (emphasis in original).