On one hand, it is difficult for produci

On one hand, it is difficult for producing parties to respond to the classic, “any and all documents, which in any way relate to…” request and on the other, it is impossible to fully comprehend the boiler plate objections “…to the extent that they are overbroad, unduly burdensome, repetitive, ambiguous, oppressive, vague, improper, and/or seek information or production of documents not relevant to the claims or defenses of any party and not reasonably calculated…” http://ow.ly/kB5h30fQRZa