Should I address items individually or broadly in a Motion to Compel Discovery? Posted on May 24, 2011

I am a defendant in a civil suit. After filing my initial response to the plaintiff's complaint, I have filed a Request for Production in order to obtain information as to the details of the items in question. I followed the form detailed in Michigan's rules closely and individually identified an enumerated list of 19 items. For most of these items, the plaintiff responded that the question is overly broad and is unlikely to provide admissible evidence. The majority of the items were a request for "Documentation in Plaintiff's possession to support plaintiff's allegation X, specifically then specific detail. A few questions: 1) Are these really overly broad and unusual requests? Am I allowed to send a revised / supplemental Request for Production with more detailed, less broad requests? 2) If these are not overly broad or unusual, when creating a Motion to Compel Discovery, do I individually address each item or do I write it in a broad way? The examples I've seen all seem to address the entire request in a broad way, but there are specific issues with the individual items, which are different (incomplete answers to some, the above objection to others)

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