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The defendant used the objection "Invasion of defendant's privacy rights, including those protections by the California

San Jose, CA |

Constitution, Article 1, Section 1" to refuse to provide his present address, previous addresses and other personal information." Is this a valid objection. What is the legal basis to compel the defendant to respond?

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Attorney answers 3


It might be a valid objection, but this all depends upon the nature of the litigation. Is it imperative that you have this information in order to prosecute your case? Is the background info reasonably calculated to lead to the discovery of admissible evidence?

If you believe you must have the responses to these interrogatories, then after making a good faith effort to meet and confer, you can make a motion to compel responses or further responses (depending upon whether the response was a pure objection or a hybird). You won't be entitled to recover reasonable attorney fees as monetary sanctions if you are representing yourself in pro per.

Frank W. Chen has been licensed to practice law in California since 1988. The information presented here is general in nature and is not intended, nor should be construed, as legal advice for a particular case. This posting does not create any attorney-client relationship with the author. For specific advice about your particular situation, please consult with your own attorney.

Hillary Johns

Hillary Johns


Or hire a lawyer to advise you as to how to handle it either representing your or on a consulting basis.


This is common. If you can prove that this information is reasonably calculated to lead to the discovery of admissible evidence in the case, then you can compel responses to the question. That means you are going to have to come up with specific factual arguments to establish that knowing where the defendant lived 10 years ago can lead to relevant evidence in the case. If you can, you will prevail. If you cannot, you will not.

Good luck to you.

This answer should not be construed to create any attorney-client relationship. Such a relationship can be formed only through the mutual execution of an attorney-client agreement. The answer given is based on the extremely limited facts provided and the proper course of action might change significantly with the introduction of other facts. All who read this answer should not rely on the answer to govern their conduct. Please seek the advice of competent counsel after disclosing all facts to that attorney. This answer is intended for California residents only. The answering party is only licensed to practice in the State of California.


The responses of the other attorneys are correct. You should be able to comple further responses to these questions if you can show that the questions are reasonably calculated to lead to the discovery of admissible evidence. What do you hope to gain from the responses? For example, will you be able to identify additional witnesses or pertinent pieces of information that may lead to the discovery of relevant evidence? Your burden to demonstrate this is not that high. However, if you cannot demonstrate that the information you seek is likely to lead to the discovery of admissible evidence, the court likely will deny your motion. Good luck.

This response is for information purpose only and does not constitute a legal advice. This response does not create an attorney-client relationship.