Wis. Stat. sec. Note that having the objection available in this form serves as a brief checklist and a reminder that the privilege extends beyond attorney work product. You can properly object on the ground that the identity of persons who investigated on behalf of a party is not discoverable. No, State ex rel. Wis. Stat. sec.
Many courts routinely require additional disclosure in the scheduling order.
These orders usually set dates for disclosures of experts and lay witnesses. I am not advocating objection to responding to discovery regarding experts or other witnesses until the date for disclosure in a scheduling order but I have seen such objections. Your opponent asks if you have any photographs of the opposing party. Your opponent asks for production of copies of all statements. You must produce that party's statement, Wis. Stat.