Calls for speculation is usually used as an objection at trial.
In discovery, either you know it or don't know it. You can be asked to "estimate" but not to "guess". You can estimate the distance to door in the room where you are now sitting. The color of the desk in my office, for you, would be a "guess."
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I dont know the local practice requirement in your state but it seems like the other side is dancing on the line of an objection but i am not sure if it would qualify as an objection. File a motion to compel discovery and lay it out to a judge. Best to have counsel making these fights if there are significant issues in play. goo luck
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Witnesses are not allowed to speculate, at trial or in deposition. Accordingly, there is an objection "calls for speculation." But that is because people can be manipulated by cross-examination questions into saying something about that which they know little or nothing.
But written discovery requires only that the responding party provide what it knows or has uncovered through reasonable inquiry, in writing, and with the assistance of counsel (if represented). So if you don't know, you can't answer, and that is the response you give. That means the question doesn't call for speculation, and the objection is improper in written discovery form.
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