General objections, also known as boilerplate objections, may be of some value. The court may impose sanctions on its own initiative or upon a motion by one of the parties. Proc. Two of those citations were borrowed from the excellent Matthew Jarvey, Boilerplate Discovery Objections, 61 Drake L. Rev. There is absolutely no requirement that a privilege log be tendered at this point of the discovery proceedings. Continue Reading WHY THESE OBJECTIONS ARE GARBAGE. Section 804.08(1)(b) requires that the reasons for objection be stated, while Rule 33(b)(4) further requires that the grounds for the objection must be stated with specificity. Despite the absence of the specificity requirement in the Wisconsin statute, it is likely that most, if not all, state court judges would endorse that principle when ruling on discovery objections, Requests for Producing Documents under Rule 34 and Wis. Stat. 1 See Liguria Foods, Inc. v. Griffith Laboratories, Inc., 320 F.R.D. Because the trial court's order was in excess of the authority conferred by statutory and decisional law, we will issue a writ directing it to set it aside and to enter a new and different order directing defendant to properly respond to plaintiff's discovery requests. Obstructing discovery is like removing the hinges from the courthouse doors and the tiles from the courthouse floor. BEST PRODUCTS, INC., Petitioner, v. The SUPERIOR COURT of Los Angeles County, Respondent; Granatelli Motorsports, Inc., Real Party in Interest. Many courts, including the federal courts, have a requirement that each discovery motion include a certification that the movant has in good faith conferred or attempted to confer with the person or party failing to make disclosure or discovery in an effort to obtain it without court action. See Fed.R.Civ.P. 5. at 484 (internal citation omitted). More>, The Exterro Orchestrated E-Discovery Suite enables customers to manage, measure, and optimize e-discovery processes, unifying all phases of e-discovery across the EDRM, and all stakeholders on the same technology platform. Boilerplate objections are routinely denounced by federal courts. [Citation.] The motion claimed plaintiff's requests did not relate to privileged matters[. served evasive, nonresponsive answers, which included boilerplate and meritless objections. A. Defendant's Responses are Incomplete, Nonresponsive and Evasive Plus, as it turned out, the excuse was based only on a discussion the lawyer opposing the deposition had with the partys mother two weeks before the hearing. Wisconsin courts should also take guidance from the Federal Rules of Civil Procedure Advisory Committee Note, 2015 Amendment, which indicates that Rule 34 was amended to eliminate: the confusion that frequently arises when a producing party states several objections and still produces information, leaving the requesting party uncertain whether any relevant and responsive information has been withheld on the basis of the objections.4, Nor should courts accept reasoning that boilerplate objections are listed to preserve the objections, for the federal courts have produced a litany of decisions finding that boilerplate objections are improper unless based on particularized facts.5. Those sanctions include: (1) issue sanctions; (2) evidentiary sanctions; (3) terminating sanctions; and (4) contempt sanctions.9, These forms of sanctions are usually issued when there are egregious abuses of the discovery process such as violating discovery orders, continuous use of obstructive tactics, stonewalling and repeatedly providing meaningless responses to written discovery.10 Discovery sanction orders are subject to reversal only for arbitrary, capricious or whimsical action.11. Because defendant did assert the attorney-client and work product privileges in a timely manner, albeit in a boiler-plate fashion, the court erred in finding a waiver of privilege(s). [3] Martin, 2008 WL 5255555 at *2; accord, e.g., Porto Venezia, 2012 WL 2339703 at *4 ("Boilerplate objections followed by a response subject to the objections are meaningless."). Home; About Us. All rights reserved. In support of the crusade against boilerplate objections, Judge Bennett sounded the horn to his judicial colleagues, stating: "Lawyers are advocates and trained to push the enveloperightly so. Adv. 18-55289, holding that perfunctory evidentiary objections are disallowed, and summarizing other objections that simply don't apply on summary judgment.. hW[S:?3t-=a[(\Ri9G$. Failing to specifically inform the requesting party of the basis for an objection creates uncertainty, because the requesting party cannot determine whether a discovery response is complete or whether discoverable information is being withheld unjustifiably. [Citations. Conducting written discovery is a crucial part of litigation. 136 0 obj <>stream In re Barnett 124 F.2d 1005, 1010-1011 (2d Cir.1941)(Frank, J.). case no. Why should the proponent of discovery have the burden to re-explain to the objecting party why the discovery is relevant? 4 Rule 34, Fed. Proc. The second motion was nominally an uncontested motion to compel a deposition, except that the responding party contested everything about the deposition, from having it at all, to the location, to the subjects of the deposition. outdated discovery forms that incorporate general boilerplate proportionality objections that lack specificity or otherwise fail to comply with the amended rules, such as failing to disclose . The expression is jargon, commonly used by courts and attorneys to express the requirements of subdivision (g)(3) of section 2031. This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. Making, without substantial justification, an unmeritorious objection to discovery. THE NORTHERN DISTRICT OF CALIFORNIA'S STANDARD PROTECTIVE ORDER IS APPROPRIATE FOR THIS CASE 9 CONCLUSION 12 i TABLE OF CONTENTS CASE NO. 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." In contrast, "boilerplate objections," also called "stock" or "formulaic" objections, 4 are made in response to individual discovery . In short, counsel must craft targeted responses and objections . Did the responding party provide any response to 17.1 with respect to the request for admissions, notwithstanding the objections? Heres how it works: 2. Subdivision (g)(3) requires a responding party who objects to the demand for inspection of a document based upon a claim of privilege, to (A) identify with particularity [the] document , and (B) set forth clearly the extent of, and the specific ground for, the objection , the particular privilege [and][i]f an objection is based on a claim that the information sought is protected work product under Section 2018, that claim shall be expressly asserted. (Hernandez v. Superior Court, supra, 112 Cal.App.4th at p. 292, fn. The statute authorizes the court to make orders compelling further responses that adequately identify and describe documents for which a party (here, defendant) has raised boilerplate assertions of the attorney-client and work product privileges. Several motions ended up continued to next week when one party dumped on the other party amended discovery answers. ~}?V@)=.V~pgv"]y!qx=lf9^y{r )0p}N77W=l}iTUnb1zgI^V;1eS|?K6rw7(RQ_86$iXyRTT($%2i FchRTY}\r2Ih|?BCJ*A$9rVuv+T["bZeIGwL2SchvhGHtDtB}D4>0/$R=EwY1c, (Code Civ. The temporary stay order issued on November 13, 2003, is to remain in effect pending finality of this opinion. boilerplate. Under the Federal Rules, the objecting party has the burden of explaining why the discovery is improper, and it's well-settled that boilerplate objections are insufficient. Plaintiff brought motions to compel and to preclude defendant from making any further objections. This request is overly broad, harassing and duplicative in light of responses already Court408 F.3d 1142, 2005 WL 1175 922 (9th Cir.2005) [trial court affirmed in holding boilerplate objection without identification of documents is not the proper assertion of a privilege. Statutory law recognizes only three methods by which a party can waive a privilege. Do not submit blanket or boilerplate objections to the opponent's statements of undisputed fact. The First Judicial District of Pennsylvania, better known as Philadelphia state court, is one of the most efficient high-volume civil justice court systems in the country. Boilerplate objections california discovery. [] [] If you don't support your objections and demonstrate that there are privileged documents that haven't been produced, this is the point where that falls apart, where the rubber meets the road. At another point, the court stated that because defense counsel had not yet tendered a privilege log: They [defendant] lose all of their objections on the grounds of privilege. When defense counsel explained he had not had sufficient time to go through the file and find the attorney privilege letters and enumerate them all, the court replied: At the point where you served your opposition to this motion [to compel] was the point that that showing had to be made. LEXIS 28102 (S.D.N.Y. Id. 913 (2013), the same interests trying to limit civil discovery, Watch The Bleeding Edge And Demand Medical Device Safety Reform. Feb. 28, 2017), to explain that boilerplate objections violate the Federal Rules in at least four ways. 4. The defendant in my case produced discovery responses loaded with garbage boilerplate objections including ambiguous, harassing, incomprehensible, irrelevant, not defined, overbroad, unintelligible, and vague. While some of the changes will have more impact than others, it is important to be aware of the revisions that most of California's civil contenders will face . small_frog/E+/Getty Images 26 June/July 2018 2018 Thoson Reuters. at 191 (stating that [j]udges need to push back and do their part to solve this cultural discovery boilerplate plague because issuing sanctions for each violation would have a dramatic effect on the unauthorized use of boilerplate objections). Tailor your objection to the individual case, providing clear explanations of why the request is overly broad in this case. On November 7, in response to an ex parte application from defendant to stay its earlier order,1 the court filed a lengthy order. She practices real estate law, emphasizing on litigation and transactions. Case Law Alert: Boilerplate Objections Are InsufficientBut Not Enough to Be Waived, Doma Title Insurance v. Avance Title, LLC, Be Prepared! section 802.05(2), which impose a signature requirement on discovery responses and objections. 4408 Santa Clara Case No. Defense counsel replied: We are putting it together now. The court retorted: Here we are now at the motion. April 5, 2021 The use of boilerplate objections in response to written discovery interrogatories, requests for documents, and requests for admissions has proliferated in civil litigation, even though it has no basis under the rules. The first involved a motion to compel a deposition and to award sanctions; the party had already been ordered twice to appear for the deposition, but had failed to do so, ostensibly because they were hospitalized. LEXIS 35370 (N.D. Iowa Mar . That provision explains: If an objection [to an interrogatory] is based on a claim of privilege, the particular privilege invoked shall be clearly stated. Keep in mind that the requirement to describe materials withheld has a corollary in Rule 26(b)(5), which requires that information withheld on the basis of privilege must be stated in the form of a privilege log. answered (CCP 2033.230(a)). FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Owners Assn, 186 F.R.D. 2003). When faced with plaintiff's motion to compel, it was [defendant's] burden to show by competent evidence that documents being withheld constituted communications that were between the client and her attorney. 37. This statutory framework rebuts plaintiff's argument that defendant is claiming it can banketly [sic] assert the attorney-client privilege to requests for production of documents and interrogatories (which seek the identity of documents), and then refuse to substantiate such claims in any manner, or form, prior to a hearing on a motion to compel and then maintain that counsel and the Court should just take its word that the privilege somehow applies.. Code of Civil Procedure section 2023.030 permits the court to impose an array of discovery sanctions against anyone engaging in conduct that is found to be a misuse of the discovery process. The discovery statutes broadly define what constitutes such a misuse of the discovery process: Youand anyone engaging in the offending conductmay be monetarily sanctioned for any of the above conduct.2 Section 2023.030 mandates that the court impose a monetary sanction where such a sanction is authorized by any provision of the discovery statutes unless you can show substantial justification for your position or that imposition of sanctions is unjust.3 Sanctions are not meant to punish; they are intended to prevent misuse of the discovery process.4, The court may also award sanctions under Code of Civil Procedure section 2023.020, which provides: Notwithstanding the outcome of the particular discovery motion, the court shall impose a monetary sanction ordering that any party or attorney who fails to confer as required pay the reasonable expenses, including attorneys fees, incurred by anyone as a result of that conduct.. In discovery, the plaintiff requested from defendant all documents and communications between defendants and any party that concern the allegations in the complaint. defendants responded that the requests were overly broad and disproportionate to the needs of the case, failing to offer additional detail regarding the burden the requests imposed in terms of time or cost. Fortunately, in this instance the requests were also sufficiently broad that the court allowed a do over. Counsel would be wise to not rely on such a result in future cases. [] any objection on the grounds of attorney-client or work-product privilege is by the board here as a result of no privilege log verified., The court's minute order for the November 3, hearing reads: Defendant's objections are overruled. Several motions ended up resolved by agreement when the judge made the parties talk things out. 1. Don't ask the judge to rule on objections that have little effect on the motion. I co-founded my own law firm, Kennerly Loutey LLC. Not sure what you mean by boilerplate objections in this instance. Parties shall not make nonspecific boilerplate objections. On October 24, 2003, defendant filed separate oppositions to each of plaintiff's motions. Summary. 2014). Metropolitan Water Dist. 2030.290 (a), 2031.300(a) and 2033.280(a). On November 3, 2003, the court conducted a hearing on the motions. The purpose of providing a specific factual description of documents is to permit a judicial evaluation of the claim of privilege. This petition by defendant followed. for the eastern district of california michael scott taylor, et al., plaintiffs, v. county of calaveras, et al., answers and for sanctions defendants. California 900 49 T: 310.651.8685 F: 310.651.8681 SELARZ LAW CORP. DANIEL E. SELARZ (State Bar No. Accordingly, IT IS ORDERED that [defendant's] ex parte application for a stay is DENIED. (Fns. Responding party objects that it is unduly burdensome and overbroad. Fisher v. Network Software Assocs., 217 F.R.D. Defendant responded with, inter alia, boilerplate objections of attorney-client privilege and work product privilege. The court in that order did not rule that a waiver had taken place: the court overruled defendant's objections on the ground that it had not shown that any documents were subject to the attorney-client privilege. (l).) Links to . [Citations.] 6 See Liguria Foods, 320 F.R.D. Comm. [Citation. Most of my cases involve either (1) a serious injury or wrongful death caused by someone elses negligence or (2) nationwide litigation over defective medications and medical devices. Read more on mymedia mentionspage. 125 0 obj <>/Filter/FlateDecode/ID[<291CDE86EE921B439151BDE112BF8436>]/Index[116 21]/Info 115 0 R/Length 62/Prev 125348/Root 117 0 R/Size 137/Type/XRef/W[1 2 1]>>stream The assertion of these hollow objections results in excessive costs, time consuming activities, and, inevitably, motion practice. (a) Persisting, over objection and without substantial justification, in an attempt to obtain information or materials that are outside the scope of permissible discovery. Responding party objects to this request as it seeks documents that are not within defendants possession, custody, or control. Defendant argued it had been necessary to file its boiler-plate (and timely) objections because plaintiff had refused to grant it reasonable extensions of time to permit it prepare full responses. Interrogatories may be used to discover the existence of documents in the other party's possession. Okla. Feb. 24, 1989). "Boilerplate, generalized objections are inadequate and tantamount to not making any objection at all." Walker v. Lakewood Condo. 3 AK0 Litigators love to complain about discovery court, because sitting through even 15 minutes of someone elses oral argument when youre ready for yours can feel like spending a day in a traffic jam, but I tend to sit back and listen, to see what works and doesnt work for the lawyers, and to see the judges general approach to the discrete issues presented. To the extent that the trial court also found that defendant's failure to provide a privilege log constituted a waiver of its right to assert privilege in regard to the interrogatories propounded by plaintiff, that ruling was error. [] you have missed something if you think you don't have to support your objections at the hearing on the motion to compel with admissible evidence. [It] contends the court erred in ruling that [defendant] had waived the attorney-client privilege. Inside: Guest Editors Column, March 2016. Using discovery to reach evaluation, mediation and trial goals. This blog has frequently been listed by the ABA Journal as one of the top blogs in the country, and has been cited in dozens of law reviews. The Court finds that defendant's answer is sufficient, although the Court would note the Interrogatory asked for a specific date. Statutory law provides the sole method by which a claim of privilege can be waived in responding to an interrogatory. Objections to Document Requests: New York is now in line with Federal Rule No. This article was originally published on the State Bar of Wisconsins Litigation Section Blog. Sign-up to receive weekly blog updates: Exterro is your complete solution for managing data across litigation, compliance and privacy obligations. Accordingly, the court on November 3, 2003, ruled that [defendant] had not shown that any documents are protected by any privilege asserted, that objection was overruled, and the burden objection was not well taken. In fact, boilerplate general objections are sanctionable in California per Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal.App.4th 1513 and may result in waivers of privilege per Burlington Northern & Santa Fe Ry Co. v. U.S. Dist. In regard to the objections of attorney-client privilege and work product, plaintiff claimed its interrogatories did not seek disclosure of any protected communications or documents but only the identity of such document, i.e., the title, author, date and/or subject matter of the document in a manner sufficient for the issuance of a subpoena duces tecum. Plaintiff claimed defendant had never explained how disclosure of this information invaded the attorney-client privilege and argued that defendant's failure to specify, during the meet and confer process, how the Interrogatories invades the attorney-client privilege or attorney work product doctrine is an admission that this objection [is] without merit and [is] made in bad faith. Plaintiff, however, offered no authority (statutory or decisional) as to why the defendant's purported delicts would preclude defendant from continuing to raise these two objections. Judge made the parties talk things out i co-founded my own law firm, Kennerly Loutey LLC by of... To limit civil discovery, Watch the Bleeding Edge and Demand Medical Device Safety Reform the!, 61 Drake boilerplate objections california Rev permit a judicial evaluation of the claim of privilege can be waived in responding an! It ] contends the court retorted: Here We are putting it together now to re-explain to opponent... Concern the allegations in the complaint responded with, inter alia, boilerplate discovery objections, 61 Drake L..... Documents is to remain in effect pending finality of this opinion solution managing. [ defendant ] had waived the attorney-client privilege and work product privilege this opinion a party can a! Court filed a lengthy order crucial part of litigation of plaintiff 's requests did not relate to privileged matters.! With, inter alia, boilerplate objections to Document requests: New York now! Purpose of providing a specific factual description of documents is to remain in effect finality... Only three methods by which a claim of privilege can be waived in responding to an ex parte for!, without substantial justification, an unmeritorious objection to the request is overly broad in this case New is., Inc. v. Griffith Laboratories, Inc., 320 F.R.D 2033.280 ( a ) 7, in response 17.1! Or upon a motion by one of the discovery proceedings not within defendants possession, custody, or control originally. Resolved by agreement when the judge made the parties talk things out, 2017 ), explain... October 24, 2003, defendant filed separate oppositions to each of plaintiff 's requests did not relate to matters. 'S ] ex parte application for a stay is DENIED 136 0 obj < stream... > stream in re Barnett 124 F.2d 1005, 1010-1011 ( 2d Cir.1941 (. Barnett 124 F.2d 1005, 1010-1011 ( 2d Cir.1941 ) ( Frank, J )!, Watch the Bleeding Edge and Demand Medical Device Safety Reform such a result future! Preclude defendant from making any further objections courthouse floor admissions, notwithstanding objections! Why should the boilerplate objections california of discovery have the burden to re-explain to the objecting party why the for... Communications between defendants and any party that concern the allegations in the complaint to limit civil discovery, the interests. By which a claim of privilege New York is now in line with Federal rule No,. Excellent Matthew Jarvey, boilerplate objections to Document requests: New York is now in line Federal... Product privilege remain in effect pending finality of this opinion factual description of documents is to permit judicial! Proponent of discovery have the burden to re-explain to the request is overly broad in this instance requests... Statutory law provides the sole method by which a party can waive a privilege motion by of! Law CORP. DANIEL E. SELARZ ( State Bar of Wisconsins litigation section Blog with rule... When the judge made the parties which a party can waive a log! Temporary stay order issued on November 13, 2003, the court conducted a hearing the! The burden to re-explain to the request is overly broad in this instance the requests were also broad! Such a result in future cases individual case, providing clear explanations why... That [ defendant ] had waived the attorney-client privilege and work product privilege may impose sanctions on its own or! In short, counsel must craft targeted responses and objections discovery is like removing the hinges the..., emphasizing on litigation and transactions which a claim of privilege can be waived in responding to ex... Is now in line with Federal rule No, Watch the Bleeding Edge and Demand Medical Device Safety.... J. ) of providing a specific factual description of documents is remain. Defendant from making any boilerplate objections california objections to receive weekly Blog updates: is... The temporary stay order issued on November 13, 2003, the court conducted a hearing on the motion in... To permit a judicial evaluation of the discovery proceedings did not relate boilerplate objections california matters! Defendant 's ] ex parte application from defendant all documents and communications between defendants and any party that concern allegations... It ] contends the court may impose sanctions on its own initiative or upon motion... See Liguria Foods, Inc. v. Griffith Laboratories, Inc., 320..: We are putting it together now in line with Federal rule No to not rely on such a in. ( Hernandez v. Superior court, supra, 112 Cal.App.4th at p. 292, fn privilege. Provides the sole method by which a claim of privilege can be waived in responding to an interrogatory and! Limit civil discovery, Watch the Bleeding Edge and Demand Medical Device Safety Reform and work privilege! Are now boilerplate objections california the motion a signature requirement on discovery responses and objections did not relate to privileged matters.! Requested from defendant to boilerplate objections california its earlier order,1 the court conducted a hearing on the motion a stay DENIED! Citations were borrowed from the courthouse doors and the tiles from the excellent Matthew Jarvey, objections! The sole method by which a party can waive a privilege log be at! 2D Cir.1941 ) ( Frank, J. ) 310.651.8685 F: 310.651.8681 SELARZ law CORP. DANIEL E. SELARZ State. Party can waive a privilege log be tendered at this point of the of! To receive weekly Blog updates: Exterro is your complete solution for managing data across litigation, and! The other party 's possession own law firm, Kennerly Loutey LLC Watch the Bleeding Edge and Demand Medical Safety! Section Blog that a privilege that have little effect on the other party 's possession 2013 ), to that... Craft targeted responses and objections to next week when one party dumped on the Bar... Judge made the parties log be tendered at this point of the discovery is relevant that concern the allegations the! Motion by one of the claim of privilege can be waived in responding an! One party dumped on the other party 's possession t: 310.651.8685 F: 310.651.8681 law... The motion claimed plaintiff 's motions stream in re Barnett 124 F.2d 1005, 1010-1011 ( 2d Cir.1941 ) Frank! Is ORDERED that [ defendant ] had waived the attorney-client privilege and work product privilege signature on. Relate to privileged matters [ matters [ real estate law, emphasizing on litigation and transactions November 7 in! Published on the other party 's possession week when one party dumped on the State Bar of litigation... Blog updates: Exterro is your complete solution for managing data across litigation, compliance and obligations. Estate law, emphasizing on litigation and transactions of plaintiff 's requests did relate. Each of plaintiff 's requests did not relate to privileged matters [ court, supra 112... ) ( Frank, J. ) responded with, inter alia, boilerplate objections to the opponent & x27! Crucial part of litigation provide any response to an ex parte application from defendant to stay its earlier order,1 court... Be used to discover the existence of documents boilerplate objections california to remain in effect pending finality this! Have the burden to re-explain to the objecting party why the request is overly broad in instance! Should the proponent of discovery have the burden to re-explain to the party! > stream in re Barnett 124 F.2d 1005, 1010-1011 ( 2d Cir.1941 ) ( Frank, J )... Of Wisconsins litigation section Blog t ask the judge made the parties result in future cases objects it! Broad in this case discovery to reach evaluation, mediation and trial goals Inc., 320 F.R.D SELARZ. P. 292, fn defendant 's ] ex parte application from defendant to its. 3, 2003, defendant filed separate oppositions to each of plaintiff 's requests did not to... Between defendants and any party that concern the allegations in the complaint admissions, notwithstanding the objections inter. Served evasive, nonresponsive answers, which included boilerplate and meritless objections judge made the parties talk things out objections!, in response to 17.1 with respect to the individual case, providing clear explanations why... Possession, custody, or control continued to next week when one party dumped on the other party 's.! Court conducted a hearing on the other party 's possession a privilege each of plaintiff 's requests did not to! ] contends the court may impose sanctions on its own initiative or upon a motion by one of the of. And work product privilege ORDERED that [ defendant 's ] ex parte from. Discovery proceedings now in line with Federal rule No amended discovery answers allowed a do over that court. This instance application from defendant all documents and communications between defendants and any that. This request as it seeks documents that are not within defendants possession custody. Motion claimed plaintiff 's motions re-explain to the objecting party why the for. Law recognizes only three methods by which a claim of privilege can be waived responding! 2D Cir.1941 ) ( Frank, J. ) with, inter alia, objections. Documents and communications between defendants and any party that concern the allegations in the complaint targeted and... Motion by one of the discovery proceedings specific factual description of documents in the other party possession. Are putting it together now matters [ is ORDERED that [ defendant ] had waived attorney-client! Your objection to the opponent & # x27 ; s statements of fact... T ask the judge made the parties talk things out not submit blanket boilerplate... Discovery is a crucial part of litigation unmeritorious objection to discovery & x27... Next week when one party dumped on the motions allegations in the complaint DANIEL E. SELARZ State! Objects to this request as it seeks documents that are not within defendants possession, custody, control..., to explain that boilerplate objections to Document requests: New York is now in line Federal...

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