Answer to Question 1
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Answer to Question 2
(1 ) the requested document or information is not within the party's possession or control, e.g. no access to a personal computer where other spouse has financial information;
(2 ) the request seeks information that is not relevant to the issues of the case, e.g., marital fault in a no-fault jurisdiction; (3 ) request creates an undue burden or expense, e.g., cost of producing request out-values the asset information sought; (4 ) the information sought is cumulative, e.g., the information sought has already been given in another form of requested discovery; and (5 ) the form of the question is improper, e.g., as asking for a party's entire medical history.
The student may also mention: (6 ) requested information is protected by a privilege; (7 ) the request is made in bad faith for the purpose of harassment; (8 ) the requested production of material is trade secret; and (9 ) the request allows the respondent to raise the Fifth Amendment right.