Legal Question in Civil Litigation in California

If you are "informed and believe," state as much in your response. Also, state that it is an approximation, so that if the number changes, you can always say I estimated that value. Depending on the nature of the objection, you may or may not respond. For instance, if the other party wants your driver's license number and the case has nothing to do with driving, you could object on the ground of privacy, and not respond further. However, if it's an automobile accident, you can still object on privacy grounds, but notwithstanding the objection, provide the driver's license number. If the discovery is abusive, you could meet and confer with the other side to try to limit the questions or requests. If that doesn't work, you could seek a protective order from the court.

I agree with Mr. Cohen. For example, if you are objecting on the grounds of privacy, you don't want to respond, because you let the cat out of the bag and you can't really claim it is private anymore.