I.e. the client’s contentions to the Form Interrogatories which ask do you contend the plaintiff was not injured in the subject incident, or that the nature and extent of the damages claimed by plaintiff were unreasonable or not caused by the incident?
If you answer that discovery has just been initiated and the interrogatory is premature – your client will very likely be served with, and have to answer, a supplemental interrogatory.
Consider framing the answer as an objection on the grounds the interrogatory seeks information protected by the attorney‑client privilege and work product rule, and that it calls for an expert opinion which the answering defendant is not qualified to give. Adding that without waiving such objections, the defendant is making no such contention at the present time, but reserves the right to amend his response after further discovery has been conducted and/or completed (i.e. you have retained and consulted with an expert witness).