Georgia objections to discovery requests. 300(a) [document requests], and 2033.

Plaintiff Claremont Stars Soccer Clubs Motion to Compel Defendant Carlos Morrell to Provide a Supplemental Response to Request Nos. 260 [document requests], and 2033. 300(a) [document requests], and 2033. Drafting Discovery – Types of discovery, when applicable, requests for admission, motions for permission to serve non-standard, and third-party discovery Speaker: Anthony J. Mayer v. FRCP 16 (b)(3)(A). The blind assertion of general objections runs contrary to the intent behind the current discovery rules—that is, the blind assertion of general objections requires the party propounding STATE OF GEORGIA , Plaintiff, v. Rules & Requirements. , Defendant. Note, on occasion, your attorney may use an informal discovery method. > > Read More. Discovery requests may relate to any unprivileged matter relevant to the subject matter of the pending action and relating to a claim or defense of any party. Dec. Nov 29, 2017 · The tautological ‘objection’ that the finder of fact can read the document for itself to see if the quote is accurate is not a legitimate objection but an evasion of the responsibility to either admit or deny a request for admission, unless a legitimate objection can be made or the responding party explains in detail why it can neither (1) If a party or an officer, director, or managing agent of a party or a person designated under paragraph (6) of subsection (b) of Code Section 9-11-30 or subsection (a) of Code Section 9-11-31 to testify on behalf of a party fails to appear before the officer who is to take his deposition, after being served with a proper notice, or fails to Instead of providing straightforward responses to Plaintiffs’ discovery requests, Defendants asserted boilerplate objections to substantially everything. 262. 2010 Georgia Code TITLE 9 - CIVIL PRACTICE CHAPTER 11 - CIVIL PRACTICE ACT ARTICLE 3 - PLEADINGS AND MOTIONS § 9-11-12 - Answer, defenses, and objections; when and how presented and heard; when defenses waived; stay of discovery O. CCP Sections 2030. Admissions, Answers or Objections . La. By means of demands for production of documents, written questions submitted (interrogatories and Requests for Admissions) and depositions (oral examination under oath before a reporter) the typical litigator in the United States will spend a hundred hours conducting discovery for every hour spent in the court room. Case No. com Dallas Office 5050 Quorum Dr. Civil Procedure Rules: Virtually all states have adopted a version of civil procedure rules which include rules dealing with discovery. Stat. The discovery request concerns the identity and location of persons having knowledge of discoverable matters; 2. 4 - Early Planning Conference and Discovery Plan If so, be sure to raise those concerns in your objections, whether in response to a specific, relevant request or in a separate “General Objections” section. The court must set a discovery cut-off date. : DEFENDANT’S RESPONSE TO PETITIONER’S FIRST NOTICE TO PRODUCE and REQUEST FOR PRODUCTION OF DOCUMENTS My name is , and I am the Respondent in the above styled case, and responds to Petitioners’ requests as follows: GENERAL OBJECTIONS 1. (NRCP 33; JCRCP 33) This language provides the framework for general principles related to asserting objections to a discovery request: objections must be stated with particularity, a principle that finds statutory support in Rule 34 and Wis. GENERAL OBJECTIONS 1. Because Defendant is requesting a method of discovery not permitted by the Maryland Rules, and which may not properly be the subject of a motion to compel, this Court should summarily deny Defendant’s Motion. See Scruggs v. 2 - Filing Requirements; Rule 5. As a general rule, when a party fails to timely object to interrogatories, production requests, or other discovery efforts, the objections are deemed waived. The problem here, however, is that Defendants have asserted meritless objections, then purported to respond “subject to The requests you receive should include very specific information about what you are being asked to do, such as sending photocopies of documents to the other party; delivering original documents to a specific location, such as a copy shop, at a particular date and time; or allowing the other party to inspect documents or things in their current location at a specific time. – 7:00 p. 26(b)(1), any discovery sought must be likely to lead to the discovery of admissible information (which, to be admissible, must be relevant). 2d 825 (1979); Suchnick v. Interrogatories may, without leave of court, be served (1) Notice of objections or motion to quash. , 243 Ga. 290(a) [interrogatories], 2031. ” Feb 16, 2017 · In Scott v. Discovery Cut-Off. Defendant’s request violates Maryland’s health records confidentiality law. v. The lesson from Nucci is that defense attorneys should exercise restraint regarding social media discovery, limiting requests to relevant and “reasonably calculated” information to overcome objections by plaintiffs regarding the discovery of social media data. In addition to stating your objections with specificity within 30 days, you should also state clearly if you intend to produce responsive documents subject to your objections, e. Some will do no written discovery or only Form Interrogatories prior to noticing the defendant’s deposition. Request No. reasonable inquiry. O. If you are served with discovery, such as a Request for Production of Feb 2, 2022 · “A discovery request may properly be quashed where the trial court has before it sufficient information upon which to decide defendant’s motion to dismiss…. Aug 15, 2020 · Objections based on over-breadth often relate to the issue of relevance of the subject matter. 2. OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. section 804. Aug 6, 2009 · 3. òGeneral Objections ó are objections that precede substantive written discovery responses and purport to apply to each response. m. Availability; procedures for use. Interstate Fire Ins. Depending on the case and the magnitude of the RFAs, you may want to confer with opposing counsel regarding any objections that impede your timely response to the RFAs. You have objected to Request No. Other CEBblog™ posts you may find useful: Shoot Back with 10 Discovery Objections; I Object! Know What Objections to Make at a Deposition Relevancy is a common objection to social media discovery. 16. Interrogatories to parties (a) Availability; procedures for use. However, the code makes it clear that the requirements in responding to Requests for Admissions are higher. One famous case where this issue arose is Oppenheimer Fund, Inc. PROPORTIONALITY OBJECTIONS TO DISCOVERY REQUESTS The 2015 amendments did not change the burden allocation among the parties. • Irrelevant: The catch all objection of “this request is not reasonably calculated to lead to the discovery of relevant, admissible evidence” is available. You 2010 Georgia Code TITLE 9 - CIVIL PRACTICE CHAPTER 11 - CIVIL PRACTICE ACT ARTICLE 5 - DEPOSITIONS AND DISCOVERY § 9-11-36 - Requests for admission O. Requests for admission (a) Scope; service; answer or objection; motion to determine sufficiency. R. 3 - Depositions Upon Oral Examination; Rule 5. (1) A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters within the scope of subsection (b) of Code Section 9-11-26 which are set forth in the request and that relate to statements or Jan 8, 2016 · By Joseph A. 9-11-33 (2010) 9-11-33. When a party to a civil case needs to get information from the other side, she can serve the other side with written requests called “discovery requests. 700 Corey Pollard is a top-rated personal injury attorney focused on recovering monetary damages for injured workers and accident victims. It is not grounds for objection that the information sought will be inadmissible at the trial if the Section 9-11-26 - General provisions governing discovery (a) Discovery methods. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property for inspection and other purposes; physical and mental examinations; and Failure to Respond to Discovery Requests . %PDF-1. The revisions, it was hoped, would particularly reduce the reliance on boilerplate and form objections to discovery. 4. When dealing with an adversary that is difficult to reason with or trust over the phone, it is best to prepare a letter that specifically outlines which discovery responses you believe are deficient and do not By means of demands for production of documents, written questions submitted (interrogatories and Requests for Admissions) and depositions (oral examination under oath before a reporter) the typical litigator in the United States will spend a hundred hours conducting discovery for every hour spent in the court room. SMI Aware works with litigants to ensure that e-discovery motions yield the For example, a Request for Admissions that asks you to admit that your defenses lack merit. 9-11-26(b)(1). 9-11-12 (2010) 9-11-12. Feb 22, 2012 · Therefore, if the initial trial date is continued and you wish to conduct additional discovery, you will need to first make a motion to reopen discovery pursuant to California Code of Civil Procedure Section 2024. A discovery request can ask what evidence the person knows, but cannot ask what a person thinks the evidence means. But your opponent has objected to it. relevant to the litigation. All requests for admission must be relevant to the issues in the case. – 6:40 p. for that party’s representative, or is otherwise protectedby any other discovery privilege recognized under the Georgia Civil PracticeAct or the laws of the State of Georgia. Admissions, answers or objections must be provided to each request. E. Without waiving any privilege or objection, Complainant responds as follows: RESPONSE: Complainant contends that the following actions (or inactions) by Agency Subdivision (g); Signing of Discovery Requests, Responses, and Objections. A party may serve upon any other party a written request for the admission, for purposes of the pending action only, of the truth of any matters within the scope of subsection (b) of Code Section 9-11-26 which are set forth in the request and 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. Multiple Discovery Requests Permitted (3) For any discovery requested from a nonparty pursuant to paragraph (2) of this subsection or a subpoena requesting records from a nonparty pursuant to Code Section 9-11-45, when the nonparty to whom the discovery request is made is not served with an objection and the nonparty produces the requested records, the nonparty shall be immune from Requests for Production of Documents are a list of documents you must allow the other party or their attorney to inspect. - File a Request for Adjudication of Discovery or Deposition Dispute (form JD-CV-119) if objections are filed within six months of the assigned trial date (Civil Matters – Statewide Standing Orders, Discovery and Deposition Dispute Order) It is also possible to request discovery objections based on the grounds that the request is irrelevant. , McLeod, Alexander, Powel and Apffel, P. Interlandi, Monarch Law, Hartford 6:40 p. law comprehensive legal database for any state court documents. I object to each interrogatory to the extent thatit purports to impose a duty or obligation upon me that is not imposed by the GeorgiaCivil Practice Act. For example, “admit you were wearing pink socks and a tutu at the time of the car accident,” is cer- Georgia Uniform Superior Court Rule 5. Case Number: 23PSCV01913 Hearing Date: July 17, 2024 Dept: K 1. Federal Discovery Objections Cheat Sheet discovery rules now force the party responding to discovery requests to think before asserting objections to an opposing party’s discovery requests. The discovery request concerns the identity of persons likely to be called as experts at trial, the subject matter on which he is expected to testify, and the substance of his testimony; 3. Defendant objects to all discovery requests to the extent they are overbroad, vague, In reality, there are very few valid legal objections to discovery in Family Law cases, unless the discovery has been sent based on a form that isn’t appropriate to the particular case or a particular discovery interrogatory or document request is so poorly written that it can’t be answered or it applies to truly irrelevant information. Objections . Whether the asking party used the Judicial Council form, Request for Admissions (DISC-020), or created their own request on pleading paper, the request will contain a numbered list of facts that you are being asked to admit, and/or a numbered list of documents, which are then also attached, that you are being asked to admit are genuine. S. 9-11-26(e)(3). Sep 6, 2021 · Office Information. Work product. Objections Based on Privilege Additional sanctions which may be imposed upon regulated utilities failing to comply with discovery requests of Public Service Commission, § 46-2-57 . Discovery is still ongoing, however, arid Defendant reserves the right to amend, supplement or change its objections and responses if and when additional information becomes available. 26(b)(1) and F. Aug 15, 2020 · This is part of Vail Law's Litigation Checklist: Objections that a discovery request is unduly burdensome, oppressive, or unreasonably duplicative are often valid, but opposing counsel will probably initially assume this is merely a "boilerplate objection. G. or subpart thereof or to any document request under Federal Rule of Civil Procedure 34, the - objection shall state with specificity all grounds. 1990). See, e. Parties may obtain discovery by one or more of the following methods: depositions upon oral examination or written questions; written interrogatories; production of documents or things or permission to enter upon land or other property for inspection and other purposes; physical and mental examinations; and requests for May 14, 2021 · Although a party receiving written discovery must generally answer the requests and produce responsive documents, certain requests may be subject to various objections. FRCP 36(a). Examples would be a statement that the responding party will limit the search to documents or electronically stored information created within a given period quasi-disclaimers at the beginning of the document, such as, “objection to the extent that any of the requests do not conform to the Illinois Supreme Court Rules or the Code of Civil Procedure. The objection must include an explanation as to why the request lacks relevance. Dec 4, 2018 · The Georgia Civil Practice Act allows parties to a lawsuit to serve requests for production of documents on nonparties as part of the process of gathering information relevant to the subject matter of the case. The requesting party must establish relevance, while the responding party must show undue burden or expense. Dahl v. g. Without waiving any privilege or objection, Complainant responds as follows: RESPONSE: Complainant contends that the following actions (or inactions) by Agency Md. It allows for parties to plan out the discovery phase as follows: “Unlike the procedure with respect to interrogatories, requests for production of documents and requests for admissions, there is no provision in the rules which provides for a party whose deposition is noticed to serve objections so as to be able to avoid providing the requested discovery until an order compelling discovery is issued. 0442 (Fax) - Trial court erred in denying plaintiffs' discovery request that sought the discovery of documents pertaining to a development loan in a lawsuit involving a dispute between joint venturers as the trial court should have applied the proper standard of relevancy set forth in O. 050, which provides: "(a) On motion of any party, the court may grant leave to complete discovery proceedings, or to have a motion (a) Discovery methods. (4) Objections to compile or process information. . Under C. P. B. 284. New requests for supplementation of prior responses. 3407 262. Quarles, 894 F. WhiteIt is common practice for litigators to respond to discovery requests by reciting a litany of objections, followed by a conditional response: “Subject to and without waiver of the foregoing objections, defendant will produce non-privileged, responsive documents…. Aug 23, 2018 · Georgia law says that parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, whether it relates to the claim or defense of the party seeking discovery. Code. Pursuant to both C. Blanket, unsupported objections that a discovery request is “vague, overly broad, or unduly burdensome” are, by themselves, meaningless, and disregarded by the Court. 210 [RFAs]. 2022 Georgia Code Title 9 - Civil Practice Chapter 11 - Civil Practice Act Article 3 - Pleadings and Motions § 9-11-12. Therefore, there are no “third part[ies]” as that term is defined. Jul 15, 2019 · Port Washington 1329 West Grand Avenue, Suite 200 Port Washington, Wisconsin 53074. Rule 2-432. Mar 30, 2017 · Nonetheless, the court limited production to all of the plaintiff’s social-media postings, including images, from the date of the accident forward that related to her alleged physical injuries or “reflect[ed] physical capabilities that are inconsistent with” the injuries she allegedly sustained because, as drafted, the discovery request Dec 1, 2007 · In Georgia, your spouse generally has thirty days to respond to your discovery requests, such as interrogatories, request to produce documents, or request to admit. " All discovery is subject to the limitations imposed by C. Section 9-11-36 - Requests for admission (a) Scope; service; answer or objection; motion to determine sufficiency. A. 26(b . 34, a document production request must designate and describe what is being sought with sufficient particularity to enable the other party to determine what documents fall within the scope of the request. A failure to timely respond to discovery waives objections. 260 [interrogatories], 2031. 9-11-36 (2010) 9-11-36. 16 on the basis that “it seeks information protected by attorney work product, attorney-client privilege and materials prepared in anticipation of litigation. ” May 15, 2017 · The one change that affects the daily work of every litigator is Rule 34, requiring that responses to discovery requests must: State grounds for objections with specificity; Objections must state whether any responsive materials are being withheld on the basis of the objection; and Jan 25, 2019 · Yes. Co. 1 - Prompt Completion; Rule 5. If the discovery to which objection is made is not a request for documents, the objection must clearly state the grounds on which the participant bases its objection. 340, 351-52 (1978). Aug 15, 2006 · The party resisting a discovery request has the burden to show why the discovery request is improper. Of course parties have a right to assert meritorious objections. Georgia Uniform Court Rules Sep 11, 2012 · Justia Free Databases of US Laws, Codes & Statutes. Those propounding discovery should promptly write to the objecting party and insist that Jul 10, 2017 · In written discovery, you’ve propounded discovery requesting your opponent to identify their social media accounts. 6:20 p. #200 Houston, TX 77024 Telephone: 713-255-4422 Fax: 713-255-4426 E-mail: info@silblawfirm. 6 %âãÏÓ 189 0 obj > endobj xref 189 43 0000000016 00000 n 0000001601 00000 n 0000001733 00000 n 0000002168 00000 n 0000002205 00000 n 0000002779 00000 n 0000003184 00000 n 0000003580 00000 n 0000004121 00000 n 0000004554 00000 n 0000005003 00000 n 0000005084 00000 n 0000005618 00000 n 0000006224 00000 n 0000006762 00000 n 0000007286 00000 n 0000007315 00000 n 0000007400 00000 n Mar 9, 2011 · Answering Requests for Admissions is very similar to answering interrogatories-you have an obligation to respond in good faith and you have to be careful about your garbage objections. The Discovery Act does not have such strident language for responding to interrogatories or an Apr 7, 2016 · 2010 Georgia Code TITLE 9 - CIVIL PRACTICE CHAPTER 11 - CIVIL PRACTICE ACT ARTICLE 5 - DEPOSITIONS AND DISCOVERY § 9-11-33 - Interrogatories to parties O. Scope; service; answer or objection; motion to determine sufficiency. He has secured over $50 million for clients in Virginia workers' compensation, Social Security disability, traumatic brain injury (TBI), spinal cord injury (SCI), product liability, and construction accident cases. 3, 16, 24-26, and 28 of the Request for Production of Documents, Set One is GRANTED. And check out CEB’s program Objections: Objecting to Written Discovery Requests, available On Demand. Any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or a governmental agency, by any officer or agent, who shall furnish such information as is available to the party. the prevailing standard with regard to pretrial and posttrial discovery requests both in Illinois and other jurisdictions is that the trial court has the discretionary power to grant If a request is not likely to lead to the discovery of relevant, admissible evidence, you may object. An objection may state that a request is overbroad, but if the objection recognizes that some part of the request is appropriate the objection should state the scope that is not overbroad. § 9-11-26, as opposed to ruling that the plaintiffs simply STATE OF GEORGIA , Plaintiff, v. Answer, Defenses, and Objections; When and How Presented and Heard; When Defenses Waived; Stay of Dis No. Responding and Objecting to Discovery – Document production, working with Jun 2, 2009 · 1. 8 For example, a boilerplate objection might state that a discovery request is “irrelevant” or “overly broad” 1. the objection without (1) specifying how the discovery request is deficient and (2) specifying how the objecting party would be harmed if it were forced to respond to the request. While defense counsel can freely access publicly available content, some courts require a showing of relevancy before allowing access to social media pages with higher privacy settings. Sep 22, 2023 · A Q&A guide on the different ways to respond to a discovery subpoena issued in a Georgia civil proceeding. For example, in a car accident case, if the propounding party asks: “Please list the names and addresses of all of your employers over the past 10 years,” you may wish to object to the request. General Objections are meaningless, and they purposely obscure substantive written discovery responses. In this post, we’ll walk through the following aspects of formal discovery: Interrogatories; Requests for Document Production and Notice to Produce (3) Objections to other discovery requests. To produce any designated documents within the general scope of discovery as outlined above, and to allow the party serving the request or his agent to inspect and copy such documents Jun 28, 2021 · A discovery plan will help set the pace and direction of litigation. D. , Ste. 15-712-BAJ-EWD (M. Sep 10, 2021 · (A) Any party may serve upon any other party a written request for the admission of the truth of any specific matter within the scope of discovery set forth in rule 3746-6-01 of the Administrative Code and subject to such discovery deadlines as the commission may order, including the genuineness of any documents described in the request. Sanctions as enforcement of absolute duty to respond. United States Postal Service, No. Failure to make discovery and motion to compel discovery in probate court proceedings, Uniform Rules for the Probate Courts, Rule 6. 09, governing requests for documents; Feb 9, 2016 · Litigation is costly, especially during the discovery phase. 436, 254 S. The resisting party must show specifically how a general objection applies to the discovery request. Requests for Production of Documents are part of “Discovery,” which is very common in court cases. Plaintiff’s counsel failed to specify the exact objection and provided little other justification For any discovery requested from a nonparty pursuant to paragraph (2) of this subsection or a subpoena requesting records from a nonparty pursuant to Code Section 9-11-45, when the nonparty to whom the discovery request is made is not served with an objection and the nonparty produces the requested records, the nonparty shall be immune from Feb 28, 2018 · When objections to discovery are raised, most jurisdictions require parties to “meet and confer” on the disputed discovery requests. Sanders , 437 U. The grounds for objecting to a request must be stated. Through a request for production, a party may require another person or entity: 1. Inadmissibility at Trial No Bar to Discovery Request > > Read More. Rule 5. This Q&A addresses the requirements for complying with a discovery subpoena, objecting to a discovery subpoena seeking documents, moving to quash a discovery subpoena, and moving for a protective order. C. Read court documents, court records online and search Trellis. See below . Responding party must serve written responses to written discovery requests within 30 days. This rule, adopted in 2015, permits parties to request such a conference, if the judge doesn’t require it. - Party properly served has an absolute duty to respond, and the court may enforce this duty by imposing sanctions for the duty's violation. As stated in the case law, the defendant objects to this request "to the extent that [the request] is overly broad and unduly burdensome". Subject to and notwithstanding this objection, in responding to these discovery requests, Plaintiff will treat the term “third party,” as extending The plaintiff requested over a decade worth of emails, letters, and other content. Document requests may specifically identify an individual document that is being sought or request an entire category of Objections: Objections may be made to all discovery questions if the questions are not relevant, or likely to lead to the discovery of relevant evidence. A participant, or a recipient of a subpoena, who does not intend to comply with a discovery request must notify in writing the participant seeking discovery within a reasonable time in advance of the date on which a response or other action in conformance with the discovery request is due. 280(a) [RFAs]. Demand Number 13009, a document request issued to Dentsply. When a court considers whether a responding party has sufficiently demonstrated that a particular discovery request Jun 22, 2020 · Plaintiff's Objections, Answers, and responses to Defendant's Interrogatories and Request for Production September 02, 2020. This objection/discovery response alone is not enough to satisfy the modern Rule 34. actually provides for a planning conference and discovery plan. You may object if the request is asking for your analysis, strategy, or thinking about the case. ” This practice serves a legitimate purpose: allowing responding parties to substantively respond to Early Rule 34 Requests > > Read More. , “[Responding party] will conduct a reasonable search and produce non-privileged documents responsive to the Request, if any, in their possession, custody, and OBJECTIONS: Complainant reiterates and restates each Objection from above, and adds that this Interrogatory requests information subject to privilege, including attorney work product. 2d 1482, 1485 (5th Cir. 27, 2016), Louisiana Magistrate Judge Erin Wilder-Doomes granted the defendant’s Motion to Compel Discovery in part, ordering the plaintiff to provide complete responses to the defendant’s interrogatory and request for production, but only after she limited the scope of both requests, determining them to be May 23, 2018 · Get practice tips and details on each of these objections in California Civil Discovery Practice, chap 7. Houston Office 950 Echo Lane, Ste. U. You must at least tell me if any responsive materials exist, so that I may seek the assistance of the Court in resolving your objection. You’ve likely also asked them to produce copies of any posts, photographs, tweets, etc. ” These requests might include: Interrogatories, which are written questions about things that are relevant or important to the case. Rule 26(g) imposes an affirmative duty to engage in pretrial discovery in a responsible manner that is consistent with the spirit and purposes of Rules 26 through 37. A lot of attorneys rely on templates or exemplars when preparing discovery requests in their personal injury cases. C. Mar 2, 2020 · Pursuant to Federal Rules of Civil Procedure 33(b)(2) and 34(b)(2), a party is to provide a written response within 30 days of receiving a discovery request. 26(b)(2)(F) for cases filed in Colorado state courts, and by F. An objection(s) to discovery is an assertion that a question or request is improper for a specific reason or the response to the same is protected from disclosure. § 9-11-34 (c)). . ” In contrast, “boilerplate objections,” also called “stock” or “formulaic” objections, 4 are made in response to individual discovery Revised Federal Rule of Civil Procedure 34 requires quick response to requests for production, specific objections to such requests, and increased clarity into what materials are being produced or withheld. Dec 17, 2021 · What are the Different Forms of Discovery? In Georgia, the discovery process is a formal way to obtain information for your case. : PLAINTIFF’S RESPONSE TO DEFENDANT’S REQUEST FOR ADMISSIONS My name is , and I am the Plaintiff in the above styled case, and I respond to Defendant’s Request for Admissions as follows: GENERAL OBJECTIONS 1. Responding to discovery is burdensome enough, but it is even more so when the opposing party issues vague, overbroad document requests that encompass information subject to the attorney-client privilege or the work-product doctrine. (O. rr ma dz id ky oy ag tt wr re