Plaintiff objects to this request on the ground that it seeks information and documents protected from disclosure by privacy laws. Magaña prevailed at trial and was awarded more than $8 million in damages. 1(e)(2)(A), which provides that, when an objection is made to any interrogatory or sub-part thereof or to any document request under Federal Rule o f Civil Procedure 34, the objection shall Boilerplate objections in responses to discovery requests are prohibited. " (record cite omitted)). Vague, Overly Broad, and Undulv Burdensome Objections that state that a discovery request is "vague, overly broad, or unduly burdensome" will be overruled bythis Court. Plaintiff objects to each document request to the extent that it calls for production of a privilege log for internal documents of Plaintiff. " Mar 29, 2024 · Objection, this request is irrelevant, overly broad, unduly burdensome and should be limited in scope and time. As with Request No. Vague, Overly Broad, and Unduly Burdensome Objections that state that a discovery request is “vague, overly broad, or unduly burdensome” are, standing alone, meaningless, and will be stricken by this Court. g. The information requested is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in this matter. Dec 20, 2014 · 8. C. If a party believes that a request or a term is vague, the party shall state the objections in writing and that party shall then attempt to obtain Cal Advocates objects to each data request to the extent it is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. (Id. Such objections will be summarily overruled. First USA Bank, No. Fed. Stat. is incorporated herein. SIUH contends that Plaintiff's Discovery Demand are so overly broad, unduly burdensome, vague and irrelevant as to warrant the Demand being vacated in its entirety. Case 1:18-cv-05102-AT Document 100 Filed 03/01/19 Page 2 of 24 A party objecting on these grounds must explain the specific and particular way in which a request is vague, overly broad or unduly burdensome … [and] claims of undue burden should be supported by a statement (generally an affidavit) with specific information demonstrating how the request is overly burdensome. a. ” Fed. Related rules The related rules section is for members only and includes a compilation of all the rules of law in Quimbee's database relating to this key term. 24 Jan 10, 2022 · In essence, recovering emails that fit the criteria of the request was not unduly burdensome, even if the search resulted in more than 40,000 records. Relator refused to produce those items. NSTRUCTIONAL . attorney-client privilege, work product doctrine, overly broad/unduly burdensome, not reasonably calculated to lead to the discovery of admissible evidence, etc. G, Response to Supplemental Notice for Discovery & Inspection). The Public Advocates Office objects to each instruction, definition, and data request to the extent request for discovery is 'over[broad] and unduly burdensome, and not reasonably calculated to lead to the discovery of material admissible in evidence,' persist despite a litany of decisions from courts, including this one, that such objections are improper unless based on particularized facts. REQUESTS FOR PRODUCTION: 1. A request for such Jan 12, 2023 · 1. ” The plaintiff complained that the defendant had used the same boilerplate language. Under Rule 26, Plaintiffs may discover any materials that are not privileged if the materials requested are reasonably calculated to lead to admissible evidence. If you do not object to a request, those objections may be waived. Oct 27, 2011 · The EEOC objected to the discovery requests and the subpoenas as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. “Irrelevant Or Not Reasonably Calculated to Lead to Admissible Evidence” Aug 14, 2015 · Therefore, to the extent Document Requests relate to companies other than these companies, such Document Requests are overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in determining whether or not SFD is amenable to jurisdiction in this district. In this age of digitization, it is becoming less common to ambiguous, overly broad, unduly burdensome, nor reasonably limited in time or scope and/or not reasonably calculated to lead to the discovery of admissible evidence. Dec 28, 2022 · Metz further objects to this interrogatory to the extent that it is vague, overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Republic objects to Instruction No. Jan 19, 2010 · Hyundai objected to many of these discovery requests as “overly broad and unduly burdensome” and produced limited documents. ”). P’s objections. burdensome, and the other party may not impose thatrequirement pursuant to the Georgia Civil Practice Act. Plaintiff objects to instruction number one (1) to the extent it purports to request Feb 15, 2018 · “The County further objects that your request is unduly burdensome. 4 on the grounds that it is overly broad, unduly burdensome, not proportional to the needs of this litigation, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. Md. ” ambiguous; (b) it is overly broad and unduly burdensome; (c) it seeks irrelevant information and information not reasonably calculated to lead to the discovery of admissible evidence; (d) it seeks, or the extent that it seeks, information protected from disclosure byVthe attorney-client privilege, work product doctrine, andlor right of privacy. 26(b)(2). Fla. However, the Court acknowledges that 4. Jul 31, 2019 · The plaintiff then repeated the same objection—“Plaintiff further objects to this request as overly broad, unduly burdensome, vague, ambiguous, and not reasonably calculated to lead to the discovery of admissible evidence”— 34 more times. Respondents object to each request to the extent that it is overly broad, unduly burdensome, oppressive, redundant, vague, and/or ambiguous. In light of the potential spoilation of evidence in this matter, court finds that the above demands are not overly broad in scope, unduly burdensome, palpably improper, or OBJECTION: Plaintiff objects to this request on the grounds that it is overly broad, unduly burdensome, vague, ambiguous, oppressive, harassment, requires speculation and judgment on the part ofPlaintiff as to what documents may or may not be responsive, and does not identify the documents to be produced with reasonable or sufficient particularity. Responding party objects to this request as it does not seek relevant documents or documents reasonably calculated to the discovery of admissible evidence. 354, 358 (D. The sheer size or burdensomeness of a FOIA request, in and of itself, does not entitle an agency to deny that request on the ground that it does not "reasonably describe" records within the meaning of 5 U. SIUH presents Andon v. Thus, the Court’s analysis will not address the other objections (vague, irrelevant, not reasonably calculated to lead to the discovery of admissible evidence, and premature). A party objecting to discovery on the basis of overbreadth must substantiate its Defendant objects to this interrogatory as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. The Court deems the remainder of the objections to be waived by Plaintiff. E. It is established by the plain language of the Rule that when either of these objections is asserted, the party making the objection must also state why the question is overly broad or unduly burdensome. 1999). Oct 8, 2019 · Responding party objects that it is unduly burdensome and overbroad. Plaintiff objects to each request to the extent that it seeks information that is confidential or which is not relevant to the subject matter involved in the pending action and is not Apr 24, 2017 · The “overly broad and unduly burdensome” objection. B. Such objections do not comply with Local Rule 26. Plaintiff objected that this request was overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Feb 17, 2020 · Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. Respondent also granted the motion for protection "in its entirety. Defendant objects to each request to the extent that it is vague, ambiguous, overly broad, unduly burdensome, oppressive, or impossible to answer fully. , 228 F. Defendants have also not raised the issue of whether the EEOC has standing to object to the subpoena served on Plaintiffs' current employers. Mar 22, 1999 · 2. The court disagrees. Cal Advocates objects to each instruction, definition, and data request to the extent that it burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. Cal Advocates objects to each instruction and data request as overly broad and unduly burdensome to the extent that it seeks documents or information that SCE will possess when it receives Cal Advocates’ opening testimony. On the other hand, requests for 9,000 documents may be unduly burdensome depending on the outcome of the public interest balancing test. Dec 1, 2015 · Holland, for example, the District Court for the Eastern District of California held that defendants' identical boilerplate objections that each request was "overbroad, unduly burdensome and oppressive, and not reasonably calculated to lead to the discovery of admissible evidence" were improper and "barred by Rule 33 and 34. If you do not know an exact number, please estimate to the best of your knowledge. Co. 9. Responding party objects that plaintiff has equal access to these documents. This request is vague, overly broad, unduly burdensome, not limited in scope, and not reasonably calculated to lead to the discovery of admissible evidence. Term used to describe a discovery request that is so vague or broad that the court finds the party served with the request cannot reasonably respond. . She argued, as relevant here, that respondent’s request for the entire memory card violated ORCP 36 because it was oppressive, overly broad, and unduly burdensome, and was not “reasonably calculated to lead to the discovery of admissible evidence. Sworn testimony or evidence may be necessary to show that a particular request is in fact burdensome. 2 because it is overly broad, unduly burdensome, and calls for documents and information beyond the statutes of limitations applicable to Plaintiffs’ claims and also is therefore not reasonably calculated to lead to the discovery of admissible evidence. THE PLAINTIFFS, By_/s/ 438109 Kelly E. 67-5. Aug 27, 2007 · The Weider Affiliates object on the bases that this request is overly broad, unduly burdensome, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. The parties also shall not make General Objections that are not tied to a particular discovery request. Such objections do burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. Ferraro, Esq. App. Below is a comprehensive list of the categories of objections that can be used for each. Two years ago, the California Court of Appeal, Second District approved a trial court's denial of broad, early stage discovery in Williams v. Cal Advocates objects to each instruction and data request as overly broad and unduly burdensome to the extent that it seeks documents or information that Sempra already Jan 29, 2010 · SIUH cross-moves to vacate Plaintiff's Discovery Demand dated October 6, 2008 due to its overly broad and unduly burdensome nature. Vague, Overly Broad and Unduly Burdensome The parties shall not make nonspecific, boilerplate objections. O. Violating the Requirements of the Federal Rules of Civil Procedure Do you respond to discovery requests in Federal civil cases with language like this?: “Defendant {or Plaintiff} objects to this request as overly broad, unduly burdensome, vague, ambiguous, and not reasonably calculated to lead to the discovery of admissible evidence. 4 Dec 21, 2018 · Request is vague, overly broad, unduly burdensome, ambiguous, not limited in time and/or scope, and not reasonably calculated to lead to the discovery of admissible evidence. This procedure does not apply to any discovery motion currently pending before the undersigned, but shall apply to any motion filed after the date of this Order. II. D. Irrelevant and Not Reasonably Calculated to Lead to Admissible Evidence: IGE adds to its standard objection that the requests are allegedly "overly broad, unduly 11 burdensome, harassing and not reasonably calculated to lead to the discovery of admissible evidence", the further charge that the financial information sought is "not relevant to the claims and defenses in this lawsuit". ” ZOOM objects to this request as vague, overly broad, unduly burdensome, harassing, and/or seeking information that is irrelevant and/or not reasonably calculated to lead to the discovery of admissible evidence. “Cleaver-Brooks objects that this [r]equest is overly broad in time and scope, *** and unduly burdensome and oppressive. IV. 10, claiming that it is overly broad, unduly burdensome, irrelevant and not reasonably calculated to lead to admissible evidence. 1982)(" the mere statement by a party that the interrogatory was ‘ overly broad, burdensome, oppressive and irrelevant’ is not adequate to voice a successful objection to an interrogatory. ANSWER: Plaintiff objects to this request as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Irrelevant Or Not Reasonably Calculated to Lead to Admissible Evidence An objection that a discovery request is not relevant must include a specific explanation describing why the request lacks relevance and/or why the requested discovery is disproportionate Plaintiff objects to each request to the extent that it is vague, ambiguous, overly broad, unduly burdensome, oppressive, or impossible to answer fully. Dec 15, 2008 · Defendant objects to this request on the grounds that it is vague, ambiguous, overly broad, unduly burdensome, not reasonably calculated to lead to the discovery of relevant information, seeks information protected by the attorney-client privilege and seeks confidential information. 18. Vague, Overly Broad and Unduly Burdensome Parties shall not make nonspecific boilerplate objections. 1. ANSWER: The Cook Defendants object to Interrogatory No. There is no way to identify the designated employees other than by reviewing the personnel files of every person who work for the defendant during the past ten years. 7. 26. Of course, even when objections such as these are deemed waived, the Court may decline to compel production when a request "far exceeds the bounds of fair discovery. litany” that the requested discovery is “vague, ambiguous, overly broad, unduly burdensome,” or that it is “not reasonably calculated to lead to the discovery of admissible evidence. SIUH's motion is denied. Parties may not automatically invoke standard objections, e. ) ("[B]oilierplate objections that a request for discovery is 'over[broad] and unduly burdensome, and not reasonably calculated to lead to the discovery of material admissible in evidence,' persist despite a litany of decisions from courts, including this one, that such objections are improper Oct 23, 2022 · The plaintiff then repeated—34 times—the same boilerplate objection: “Plaintiff further objects to this request as overly broad, unduly burdensome, vague, ambiguous, and not reasonably calculated to lead to the discovery of admissible evidence. However, overbroad is not a valid objection unless it can be shown that the request imposes an undue burden or seeks discovery that is not relevant to the subject matter of the case. 8. Aug 14, 2015 · Therefore, requests for documents prepared, written, sent, dated, or in effect prior to January 1, 1997 or after January 31, 2001 seek documents that are irrelevant and such requests are overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in determining whether or not SFD is amenable to Aug 15, 2020 · An overly broad discovery request lacks specificity as to time, place, and/or subject matter being requested. This may include information about how the requested documents are likely stored, indexed, or otherwise accessible. the definition of “identify” is overbroad, unduly burdensome, not proportional and seeks information that is not reasonably calculated to lead to the discovery of admissible evidence relevant to jurisdictional issues. Plaintiff objects to instruction number one (1) to the extent it purports to request The parties shall not make nonspecific, boilerplate objections. ” The court now will address plaintiff E. I object to each interrogatory to the extent thatit is vague, ambiguous, overly broad, unduly burdensome, oppressive, or impossible to answerfully. 3d 321 and seemed to "promote the philosophy of proportionality drafted into the proposed amendments to the Federal Rules of Civil Procedure. 5. INSTRUCTIONAL OBJECTIONS 1. Heard objects to the request to the extent it is vague, ambiguous, overly broad, unduly burdensome, seeks documents not relevant to the claims or defenses of any party, or is not proportional to the needs of the Mar 7, 2013 · The objections waived are those set forth in familiar boilerplate: vague, over-broad, unduly burdensome, not reasonably calculated to lead to discovery of admissible evidence. , 677 F. BJECTIONS. Vague. Plaintiffs object to this demand as overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. Copies of any and all motion pictures, video tapes, security videos or photographspertaining to any fact or issue involved in this controversy. Responsive documents will likely include records that are exempt from disclosure, such as records that reveal the privileged and confidential deliberative process and attorney-client privileged communications, as well as other confidential communications. Dec 9, 2022 · No. D. was ‘overly broad, burdensome, oppressive and irrelevant’ is not adequate to voice a successful objection to an interrogatory. Cleaver-Brooks further objects because this [r]equest does not specify with reasonable particularity the documents sought and seeks information that is neither relevant nor reasonably calculated on the grounds that it is overly broad, both in substance and temporal scope (unlimited), unduly burdensome, vague, ambiguous and it is not reasonably calculated to lead to the discovery of admissible evidence; it calls for irrelevant and immaterial information and documents that are beyond the scope of discovery prohibited by Rule 26(b). ) 5:14-cv-11240-JCO-MKM Doc # 93 Filed 05/08/15 Pg 5 of 10 Pg ID <pageID> Plaintiffs object to this demand as overly broad, unduly burdensome and irrelevant to Plaintiffs' claims herein and not reasonably calculated to lead to the discovery of admissible evidence. Rptr. As to claims that some of the information request is vague, overly broad, or unduly burdensome. 26(b)(1). § 552(a)(3)(A). Defendant further objects on the grounds that Request No. 4th 1151, 187 Cal. Defendants object to the Interrogatories and Requests for Production of Documents to the extent that they are overly broad, unduly burdensome, oppressive, and/or seek information that is not relevant to the issues in this lawsuit or reasonably calculated to lead to the discovery of admissible evidence. ) (“[B]oilierplate objections that a request for discovery is ‘over[broad] and unduly burdensome, and not reasonably calculated to lead to the discovery of material admissible in evidence,’ persist despite a litany of decisions from courts, including this one, that such objections are RESPONSE: Objection; overly broad, unduly burdensome, not reasonably limited in time or scope, and not reasonably calculated to lead to the discovery of relevant or admissible evidence and/or not within the Plaintiff’s knowledge. with the service requirements of the state of New York, including but not limited to CPLR 2103(a), CPLR 311, and/or CPLR 308. Despite courts' repeated admonitions that Jun 29, 2020 · 2. broad and unduly burdensome and seeks information not reasonably available to plaintiff. Notwithstanding these objections, plaintiff provided “medical record authorizations” for Providence Medical Center and Walgreens. , 253 F. 10 seeks relevant information that is reasonably calculated to lead to admissible evidence. I. Apr 24, 2019 · On January 4, 2019, Respondent signed an order granting the motion and holding that the proposed discovery is overly broad, harassing, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Magaña did not move to compel further discovery at that point, nor did Hyundai move for a protective order. Berkowitz and Hanna LLC 2 Corporate Drive, Third Floor Shelton, CT 06484 Tel. Also the request is not reasonably calculated to lead to discovery of admissible evidence. Defendant objects to each request to the extent that it seeks information that is confidential or which is not relevant to the subject matter involved in the pending action B. 6, this request is properly limited in scope. 1 to May 1, 2024 · Defendants’ response to request No. (203) 324-7909; Fax (203 Sep 11, 2018 · OBJECTION: Defendant objects to this interrogatory as it is overly broad, unduly burdensome, immaterial, unduly intrusive, not reasonably calculated to lead to the discovery of admissible evidence and/or seeks information without the requisite showing of need. undefined, overly broad, unduly burdensome, and calling for irrelevant information not reasonably calculated to lead to the discovery of admissible evidence. The Cook Defendants further object to Interrogatory No. Jun 21, 2006 · Defendant objects to these requests on grounds that they are vague, ambiguous, overly broad, unduly burdensome, not reasonably limited in time or scope and seek information that is not relevant or reasonably calculated to lead to the discovery of admissible evidence. 1(G)(3)(a) which provides “Where an objection is made to any interrogatory or sub-part thereof or to any document request under Aug 14, 2015 · To the extent an interrogatory relates to the Smithfield Companies, such interrogatory seeks information that is irrelevant and is overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in determining whether or not SFD is amenable to jurisdiction in this district. 2008) (Grimm, M. Health & Policy Studies, Inc. ” 23 On the other hand, the court also provided that when an objection claims irrelevance, the party pro - pounding the discovery has the obligation to establish how the request is relevant. See Fischer , 2017 WL 773694, at *3 (“[S]tating that the requests are ‘overly broad and unduly burdensome’ is meaningless boilerplate. Plaintiff objects to each document request and interrogatory that is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. 98–8238, 1999 WL 1212561 (N. 2005) ("I, like all members of the federal judiciary, have concluded that '[a]n objection must show specifically how an interrogatory is overly broad, burdensome or oppressive, by submitting affidavits or offering evidence which reveals the nature of the burden 2. ” Swift v. The request is overly broad or unduly burdensome. P. Respondents object to each request to the extent that it seeks to impose on Respondents obligations greater than or different from those imposed under the not reasonably calculated to lead to the discovery of admissible evidence and protected by a privilege" (Exh. Absent more, this “objection” is useless. R. Subject to and without waiving said objections, all responsive documents will be produced upon the execution of a Stipulated Protective Order. Defendant objects as the request seeks information that is vague, overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. 10. While the scope of discovery is not limited to what is admissible in trial, Plaintiff’ s income tax returns are not reasonably calculated to lead to any discovery which is admissible and has been requested for the purpose of harassment. Specifically, Defendant objects to any documents responsive to this request which are protected by the attorney-client privilege Cal Advocates objects to each data request to the extent that it is overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. "[15] The court Defendant objects that this request is vague, ambiguous, overly broad, unduly burdensome, not reasonably calculated to lead to admissible evidence, and requests information which is proprietary and confidential. S. Copies of any inspections and/or inspection reports of the subject property within the past five (5) years [that] appears reasonably calculated to the discovery of admissible evidence. Center for Corr. Ms. ("SFD") is amenable to jurisdiction in this district. Smithfield Companies objects to the Document Requests as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence in determining whether or not Smithfield Foods, Inc. ”); grounds that the request “is overly broad, unduly burdensome, or harassing … has the obligation to offer an adequate defense to the grounds claimed. " ). Second, the County argued that a search based on such broad parameters would garner records that did not substantively relate to the conduct of the public’s business. C. If a party believes that a request or a term is vague, that party shall attempt to obtain clarification from Apr 10, 2008 · Harris Corp. Superior Court (2015) 236 Cal. Ill. not reasonably calculated to lead to admissible evidence; overly broad in time, scope, corporate structure; unduly burdensome; too vague to be answered; What is the time limit for a party to respond to RFPs? 30 days to respond to the request, and then a reasonable time afterwards to complete the location and culmination of the requested documents Based on these two cases, FOIA officers and requesters have a general idea that a request for 50 e-mails plus attachments is not unduly burdensome. as being applicable to all the requests. Civ. " This original proceeding followed. The request is not specifically tailored to discover relevant information for this loan account and Defendant has not shown how this information is important to their case. Feb 28, 2017 · Co. R. Unless impractical, an objection that the definition of “identify” is overbroad, unduly burdensome, not proportional and seeks information that is not reasonably calculated to lead to the discovery of admissible evidence relevant to jurisdictional issues. 2d 985, 992 (3d Cir. 40, 44 (D. ” [Dkt. The Court finds that Plaintiffs’ Interrogatory No. RESPONSE:Objection. Oct 3, 2022 · Plaintiff objects to this request as overly broad, unduly burdensome, vague, and not reasonably calculated to lead to the discovery of admissible evidence. 3. 4 is: “Defendant objects to Request No. Jun 30, 2017 · 2. " overly broad and unduly burdensome objections only. Metz further objects to this document request to the extent that it seeks privileged or confidential information. 4. ] When an objection generally asserts that the interrogatory or request is “vague, ambiguous, overly broad, unduly burdensome or that it is Objection: The deponent objects to said request on the grounds that said request is overly broad, unduly burdensome and not reasonably calculated to lead to discovery of admissible evidence. A request for such Interrogatory 13 is “overly broad unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence. That would include Jan 10, 2014 · Response: Objection. J. Overbreadth Objection. In addition, claims of undue burden should be supported by a statement (generally an affidavit) with specific information demonstrating how the request is overly burdensome. overly broad, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence. Overly Broad, and Unduly Burdensome Objections that state that a discovery request is "vague, overly broad, or unduly “Vague, Overly Broad and Unduly Burdensome” Parties shall not make conclusory boilerplate objections. Dec 24, 2008 · believes that all of the discovery sought is relevant, it is inarguable that it is at least “reasonably calculated to lead to the discovery of admissible evidence. Any response due, to the extent they exist, will be produced. I object to each interrogatory to the extent thatit seeks information that is In litigation, written discovery typically consists of (1) Requests for Production, (2) Requests for Admission, and (3) Interrogatories. Defendant objects to each of the interrogatories to the extent they are vague, ambiguous, overly broad, unduly burdensome, and/or seek information or documents that are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence. The propounding (requesting) party must include enough information to make the requested documents easily identifiable. 1 as it is overly broad, unduly burdensome and not reasonably calculated to lead to the discovery of admissible evidence to the extent that it seeks “each and every act or omission” on Plaintiff's part.
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