Defendants objected to the sought-after discovery on a number of grounds. As the Court has previously advised, under Federal Rule of Civil Procedure 26(b)(1), discovery is permitted of “any nonprivileged matter that is relevant to any party’s claim or defense;” Rule 26(b) is to be “liberally interpreted to permit wide-ranging discovery of information;” and the burden here is on defendants to show that the discovery being sought by plaintiff should not be allowed. See August 13, 2013, Order Re Plaintiff’s Motion to Compel Further Responses to Requests for Production of Documents, Interrogatories, and Requests for Admissions (“August 13 Order”), at 2. Nevertheless, “[d]iscovery must be narrowly tailored ... and must not be a fishing expedition.” Zewdu v. Citigroup Long Term Disability Plan, 264 F.R.D. 622, 626 (N.D. Cal. 2010) (citing Groom v. Standard Ins. Co., 492 F.Supp.2d 1202, 1205 (C.D. Cal. 2007) ).

Defendants assert the attorney-client privilege as to certain documents. An entity that withholds discovery materials based on a privilege must provide sufficient information (i.e., a privilege log) to enable the requesting party to evaluate the applicability of the privilege or other protection. Fed.R.Civ.P. 26(b)(5); see Clarke v. Am. Commerce Nat’l Bank, 974 F.2d 127, 129 (9th Cir. 1992). Failure to provide sufficient information may constitute a waiver of the privilege. See Eureka Fin. Corp. v. Hartford Acc. & Indem. Co., 136 F.R.D. 179, 182-83 (E.D. Cal. 1991) (a “blanket objection” to each document on the ground of attorney-client privilege with no further description is clearly insufficient); Peat, Marwick, Mitchell & Co. v. West, 748 F.2d 540, 542 (10th Cir. 1984) (attorney-client privilege waived when defendant did not make a timely and sufficient showing that the documents were protected by privilege). Asserting a “blanket objection” to document requests will be found to be insufficient and improper. Davis v. Fendler, 650 F.2d 1154, 1160 (9th Cir. 1981) (blanket privilege objection is improper); seeClarke, 974 F.2d at 129 (blanket assertions of privilege are “extremely disfavored”). The attorney-client privilege applies only when “(1) legal advice is sought (2) from a professional legal advisor in his capacity as such, and (3) the communications relating to that purpose (4) are made in confidence (5) by the client.” Griffith v. Davis, 161 F.R.D. 687, 694 (C.D. Cal. 1995). Defendants have set forth no evidence establishing that counsel was contacted for the purpose of providing legal advice about the documents or information to which they are objecting. Thus, the purpose of the privilege -- to protect disclosures necessary to obtain informed legal advice and to encourage “full and frank disclosure by the client to his or her attorney” -- has not been shown to be implicated here. Clarke, 974 F.2d at 129. The Court will not sustain an objection by defendants on this ground unless it is abundantly clear that the privilege attaches to any of the requested documents. Neither can the Court conclude that the work product doctrine protects any of the requested documents. Rule 26(b)(3) of the Federal Rules of Civil Procedure may “protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of a party’s attorney ... concerning the litigation.” The work product doctrine “is intended to preserve a zone of privacy in which a lawyer can prepare and develop legal theories and strategy ‘with an eye toward litigation,’ free from unnecessary intrusion by his adversaries.” United States v. Adlman, 134 F.3d 1194, 1196 (2nd Cir. 1998) (quoting Hickman v. Taylor, 329 U.S. 495, 511, 67 S.Ct. 385, 91 L.Ed. 451 (1947) ). Furthermore, “[t]o be entitled to the protection of the work product rule, the material must have been generated in preparation for litigation. The prospect of future litigation is insufficient.” Whitman v. United States, 108 F.R.D. 5, 9 (D.N.H. 1985). No showing that documents were generated in preparation of litigation has been made by defendants here; accordingly, this doctrine does not shield the requested documents.

*2 Next, defendants object to producing some of the requested documents based on “individuals’ rights to privacy under the federal and state constitutions.” (See, e.g., Motion, Ex. 13 at 2). Nevertheless, the Court finds that certain of the information sought by plaintiff in the Motion is relevant to plaintiff’s claims in the pending action (see infra), and further finds that plaintiff’s need for the discovery outweighs any alleged privacy interest of defendants or third parties whose information may be produced. See Unger v. Cohen, 125 F.R.D. 67, 70-71 (S.D.N.Y. 1989); Tyner v. City of Jackson, 105 F.R.D. 564, 565-66 (S.D. Miss. 1985) (“A basic function of federal courts is to facilitate the ascertainment of truth in resolving disputes ... [I]nvestigative reports regarding other similar incidents involving any of the individual police officers are also either relevant or will lead to the discovery of admissible evidence.”); Ragge v. MCA/Universal Studios, 165 F.R.D. 601, 604-05 (C.D. Cal. 1995) (the right to privacy is not absolute, but is “subject to invasion depending upon the circumstances”). Moreover, the Court finds that a protective order would strike the appropriate balance between the need for the information and the privacy interests of defendants and third parties. See, e.g., King v. Conde, 121 F.R.D. 180, 191-92 (E.D.N.Y. 1988) (rejecting police officers’ claim of privacy interest in their professional personnel records); Knoll v. Am. Tel. & Tel. Co., 176 F.3d 359, 365 (6th Cir. 1999) (approving of protective orders to protect non-parties from “the harm and embarrassment potentially caused by nonconfidential disclosure of their personnel files”); Hutton v. City of Martinez, 219 F.R.D. 164, 167 (N.D. Cal. 2003) (production of medical records and worker’s compensation files under protective order adequately safeguarded privacy concerns).

In determining the scope of production, the Court is cognizant of the directive that the Federal Rules of Civil Procedure, including those rules concerning discovery, be administered in such a way so as “to secure the just, speedy, and inexpensive determination of every action and proceeding.” Fed.R.Civ.P. 1. The Rules also impose a duty on the Court to limit the extent of discovery otherwise allowed if “the burden or expense of the proposed discovery outweighs its likely benefit.” Fed.R.Civ.P. 26(b)(2)(C)(iii). To this end, the Court finds it appropriate to limit to some extent various aspects of plaintiff’s requests, including the time frame sought by plaintiff for certain documents and information.

Finally, the Court here applies the same standards with regard to defendants’ objections based on relevance, vagueness, ambiguity, and overbreadth as in prior Orders. See, e.g., February 11, 2014, Order Re Plaintiff’s Motion to Compel Further Discovery Responses (the “February Order”); August 13 Order; and August 12, 2013, Order Re Plaintiff’s Motion to Compel Compliance with Subpoena Served on Arrowhead Regional Medical Center. (See Docket Nos. 69, 70, 106). Plaintiff is alleging that defendants failed to properly examine and treat him following his arrest on November 17, 2010, and he is entitled to information about his treatment at WVDC and ARMC, the facilities themselves, and the individuals who attended to that treatment at the facilities.

Accordingly, the Court overrules defendants’ objections with regard to relevance, vagueness, overbreadth, attorney-client privilege, and privacy, as well as other stated objections, and grants plaintiff’s Interrogatories for WVDC, Nos. 21 and 22 (Set 5); Requests for Admissions for WVDC, Nos. 78, 79, 80, 81, 90, 91, 92, 101, and 102 (Set 4); Requests for Production for Joseph Florin, Nos. 2, 4, and 5 (Set 1), and 6 (Set 2); Interrogatory for Pamela Lux, No. 14[1] (Set 3); and Request for Production for Pamela Lux, No. 2 (Set 1).

Plaintiff’s Motion is denied as to those discovery requests where the Court has determined that the Request has been asked and answered, is vague or ambiguous, or calls for speculation. Specifically, the Court denies plaintiff’s Request for Production for WVDC, No. 30 (Set 5); Interrogatories for WVDC, Nos. 14 (Set 4) and 25 (Set 5); Requests for Admissions for WVDC, Nos. 75, 76, 77, 96 and 97 (Set 4); Request for Admission for Joseph Florin No. 71 (Set 3); and Interrogatories for Pamela Lux, Nos. 15 and 17 (Set 3).

*3 Bearing in mind the above principles, plaintiff’s Motion as to the remaining Requests and Interrogatories is granted in part and denied in part, as follows:

A. Subpoena Duces Tecum for ARMC - denied

Plaintiff requested all of non-party ARMC’s “policies, procedures, customs and/or practices ... in effect” on the relevant dates; “all” of ARMC’s “meta data” pertaining to the “viewing and/or transferring of the plaintiff’s medical records” during an approximately five-month period; “any and all training records” for defendants Lux and Florin; and various other records that plaintiff also requests of defendants in this action. (See Motion, Ex. 2 at 4-5). ARMC objected to the subpoena based on improper service and as the subpoena “exceeded the geographic boundaries for production under [Fed.R.Civ.P. 45].” (See Motion, Ex. 4). In the Opposition, defendants assert that the subpoena “was never served on ARMC, a non-party to this action and an entity not currently represented in ths litigation.” (Opposition at 12). Plaintiff asserts that service was proper because “he served it on counsel for the non-party [ ]ARMC[ ].”[2] (Response at 50). As defendants indicate that ARMC is “not currently represented in this matter,” however, plaintiff’s service on County Counsel was not proper as to ARMC. (SeeOpposition at 12); see Fed.R.Civ.P. 45(b)(1). As to plaintiff’s attempted service by mail, “[t]he longstanding interpretation of Rule 45 has been that personal service of subpoenas is required. The use of the word ‘delivering’ in subdivision (b)(1) of the rule with reference to the person to be served has been construed literally.” Wright & Miller, 9A Fed. Prac. & Proc. Civ. § 2454 (3d ed.) (footnotes omitted); accord, 9 Moore’s Fed. Prac. § 45.21 (3d ed. 2010) (noting that a majority of courts require personal service of subpoenas duces tecum); see alsoPrescott v. Cnty. of Stanislaus, 2012 WL 10617, at *3 (E.D. Cal. Jan. 3, 2012). As the subpoena was not properly served on ARMC, the Court will not compel compliance with it.

B. Requests for Defendant WVDC

Request for Production No. 27 - granted in part

In Request for Production No. 27 (Set 4), plaintiff seeks from WVDC the “[a]nnual [w]ork performance evaluations” of defendant Keith Miller for the years 2007-10. (Motion, Ex. 7 at 2-3). WVDC objected on the grounds, among others, that the Request is “overbroad,” and that “plaintiff has already been informed that Miller has never been reprimanded for failing to follow WVDC medical policies, procedures, or standards of care, in Request for Interrogatory No. 8.” (Id.).

To the extent defendant WVDC objects on the ground that plaintiff has already been informed of the lack of reprimands in defendant Miller’s personnel history, the Court notes that plaintiff’s Request may well yield relevant information that goes beyond the previously disclosed information. Accordingly, the Court overrules defendant’s objections, and orders WVDC to respond to this Request, but limited to production of records for the years 2007-2010 that contain findings or conclusions that Miller was indifferent to the medical needs of patients, or performed in a deficient manner with regard to evaluating and treating patients. If no such records exist, WVDC, through a staff representative, shall so state in a declaration.

Interrogatory No. 15 - granted in part

*4 In Interrogatory No. 15 (Set Four), plaintiff requests the “names, addresses and telephone numbers” of several WVDC employees “who had interaction with him” between November 17, 2010, and December 3, 2010. (Motion, Ex. 8 at 2). Defendants’ opposition states that WVDC “does not know whether plaintiff is requesting the personal information of the individuals or their work contact information.” (Opposition at 3). To the extent plaintiff seeks the work contact information for certain WVDC personnel, his Interrogatory is granted. To the extent the Interrogatory may be a request for these individuals’ “personal information,” plaintiff’s Interrogatory is denied.

Interrogatory No. 16 - granted in part

In Interrogatory No. 16 (Set 5), plaintiff requests the “names, addresses, and telephone numbers of all witnesses for the defendants which [sic] have any knowledge regarding the incidents in this current litigation.” (Motion, Ex. 9 at 2). WVDC objects on the ground, among others, that the Interrogatory is “vague and ambiguous as to [the terms] ‘any knowledge’ and ‘incident.’ ” (Id.).

The Court finds that plaintiff’s Interrogatory is not vague or ambiguous, as plaintiff limits the scope of the Interrogatory to those individuals whom this defendant has already identified as witnesses in this action. (See Motion, Ex. 9 at 2). To the extent plaintiff’s Interrogatory includes individuals identified by defendant as witnesses who are not employed by WVDC, his Interrogatory is granted. To the extent plaintiff seeks contact information for employees of WVDC, his Interrogatory is granted, in part, but only as to those individuals’ work contact information.

Interrogatory No. 17 - denied

In Interrogatory No. 17 (Set 5), plaintiff asks whether it is WVDC’s contention that it has provided plaintiff “with all [defendant] Miller[’]s training records from [five] years prior to the incident to the present in [its] response to interrogatories, set three, yes or no, [sic] [i]f no please explain.” (Motion, Ex. 9 at 2). Defendant WVDC responded by indicating that “[n]o records have been provided in response to interrogatories.” (Id.). In the Motion, plaintiff asserts that he “made a typographical error and used the word [‘]interrogatories[’] instead of [‘]production[’].” (Motion at 7 of 29). WVDC, in its opposition, argues that plaintiff “seeks to now modify his question, without providing a legitimate reason why he could not have propounded a new request prior to the discovery cut-off ... A motion to compel is an inappropriate forum to seek to compel a response to a newly modified request within the Motion.” (Opposition at 4).

WVDC served its Response to Plaintiff’s Interrogatories, Set Five on January 31, 2014, which was still within the discovery period. (Motion, Ex. 9 at 6). The Court sees no reason why plaintiff could not have propounded this Interrogatory at an earlier time in the discovery period, and/or propounded a corrected Interrogatory once the objection was received. No further response is warranted.

Interrogatories Nos. 18, 24, Request for Admission No. 100 - granted

With respect to Interrogatory No. 18 (Set 5), WVDC objected on the grounds that the request “lacks foundation,” and “assumes facts incorrectly.” (Motion, Ex. 9 at 2). In its Opposition, defendant writes that “the only request defendant has with the language cited by plaintiff contains a date of [October 18, 2010],” and not November 18, 2010, as indicated in the Interrogatory. (Opposition at 4). “Thus, defendant properly objected that the request was argumentative, because WVDC never made such a contention and it lacked foundation and assumed facts incorrectly.” (Id.).

*5 With respect to Interrogatory No. 24 (Set 5), WVDC objected on the grounds that the request is argumentative, vague and ambiguous, and compound. (Motion, Ex. 9 at 4). Defendant objects to plaintiff’s Request for Admission No. 100 on the ground, among others, that the Request “[a]ssumes facts incorrectly.” (Motion, Ex. 10 at 10). Defendant’s Opposition further explains that, as to both Requests Nos. 24 and 100, as “[d]efendant does not have a[n] [October 18, 2010] request,” plaintiff’s Interrogatory is “argumentative because it asks defendant to assume facts in order to respond.” (Opposition at 5).[3]

As explained in its Opposition, WVDC’s objections to these discovery requests are based on a single issue, involving the date-as-written on one of plaintiff’s health services request forms, which the Court addressed in its February Order, noting that plaintiff referred to a Health Services Request erroneously dated October 18, 2010, as being dated November 18, 2010. (See February Order at 5).[4] As WVDC had notice of the resolution of this issue, and as WVDC appears to acknowledge that the substance of the discovery requests refers to the November 2010 events at issue in this matter, defendant must respond to Interrogatories Nos. 18 and 24 (Set 5), and provide a further response to Request for Admission No. 100 (Set 4).

C. Requests for Defendant Joseph Florin

Request for Production No. 7 - granted in part

In his Request No. 7 (Set 2), plaintiff requests “any kind of work performance evaluations for this defendant Joseph Florin five years prior to the incident on [November 17, 2010,] to the present.” (Motion, Ex. 13 at 2). Florin objects on the grounds, among others, that the Request is “[o]verbroad as to scope and time.” (Id.).

The Court grants this Request but only as to the four-year period of time beginning two years prior to November 17, 2010, and ending two years after, and only with regard to records containing findings or conclusions that Florin was indifferent to the medical needs of patients, or performed in a deficient manner with regard to evaluating and treating patients. If no such records exist, Florin shall so state in a declaration.

Requests for Admissions Nos. 41, 42, 43, 44 - denied

In his Requests Nos. 41 and 42 (Set 3), plaintiff asks that Florin admit that Exhibits 9 and 10 are “true and correct cop[ies]” of x-rays taken of plaintiff’s chest and left shoulder by WVDC staff at various times on December 2, 2010, and “forwarded to the ARMC radiology department by Dr. Liong[,] a WVDC Medical Doctor.” (Motion, Ex. 14 at 4-5).[5] In Requests Nos. 43 and 44 (Set 3), plaintiff asks that Florin admit that Exhibits 11 and 12 are “true and correct cop[ies]” of x-rays taken of plaintiff’s chest at various times on December 2, 2010, and December 3, 2010, at ARMC. (Motion, Ex. 14 at 5).[6]

*6 Florin objects on the grounds, among others, that the Requests “lack[ ] foundation, call[ ] for speculation, and call[ ] for expert opinion.” (Motion, Ex. 14 at 5).

The Court agrees with Florin that the Requests call for expert opinion as to the identity of the subject of the x-rays, and with regard to Requests Nos. 41 and 42, call for speculation by Florin as to the subject of the x-rays and whether the x-rays were taken by WVDC staff. No further response is required.

Request for Admission No. 51 - denied

In his Request No. 51 (Set 3), plaintiff asks that Florin admit that plaintiff “was brought to ARMC by the Fontana police department as a trauma consult patient so that he could be medically cleared for jail at WVDC.” (Motion, Ex. 14 at 7). Defendant objects on the ground, among others, that the Request calls for speculation. (Id.). In his Response, plaintiff indicates that a “discharge summary” from ARMC “contains the specific information needed for defendant to admit or deny” this Request. (Response at 34; Response, Ex.17).

As defendant Florin has already testified as to his recollection regarding plaintiff’s arrival at ARMC (Response, Ex. 18 at 10-11), and his testimony indicates that he lacks an “independent recollection” as to how plaintiff arrived, the Court agrees with defendant that the Request calls for speculation. No further response is required.

Request for Admission No. 55 - granted

In his Request No. 55 (Set 3), plaintiff asks that defendant Florin admit that he “never determined the cause of plaintiff’s respiratory pain with inspiration, which was noted in Rachel Sugerman’s triage assessment taken on the night of [November 17, 2010,] at 2348 [hours].” (Motion, Ex. 14 at 8). In his Opposition, defendant asserts that the Request is improper “because it requires [defendant] to assume a fact not in evidence; that is, that [plaintiff] had pain with respiration.” (Opposition at 10).

Under the circumstances, as defendant Florin previously testified that he “[did not] know,” “the source, if any, of [plaintiff’s] pain with inspiration,” defendant’s objections are overruled, and defendant is ordered to provide further response to this Request. (See Response at 35-36; Response, Ex. 18 at 56).

Requests for Admissions Nos. 63, 64, 65, 66, 67 - denied

In his Request No. 63 (Set 3), plaintiff asks that defendant Florin “[a]dmit it is ARMC’s and your custom or practice to order a chest x-rayafter the plaintiff made the complaint of chest pain on the night of [November 17, 2010,] at 2348 hours.” (Motion, Ex. 14 at 11). Requests Nos. 64, 65, 66, and 67 (Set 3) each make essentially the same request, replacing “chest pain” with “thumb pain” (Request No. 64), “shoulder pain” (Request No. 65), “back pain” (Request No. 66), and “respiratory pain” (Request No. 67). (Motion, Ex. 14 at 11-12). Florin objects to each Request on the ground, among others, that each is compound. (Motion, Ex. 14 at 11-12). As plaintiff combined Florin’s and ARMC’s customs into each Request, the Court agrees with Florin, and no further response is warranted.

Request for Admission No. 73 - denied

In his Request No. 73 (Set 3), plaintiff asks that defendant Florin “[a]dmit that the ARMC emergency department nursing progress notes/procedures and treatments refer to the plaintiff’s 10 out of 10 pain.” (Motion, Ex. 14 at 14). Florin objects on the ground that the Request is vague and ambiguous as to the documents referred to by plaintiff.

*7 Plaintiff, in his Response, attaches a “two page document,” entitled “Emergency Department Progress Notes,” that he refers to as “deposition ‘Exhibit C’ ” (“Exhibit C”). (Response at 39; see also Response, Ex. 18 at 167-68). Plaintiff asserts that “[d]efendant knows exactly what documents the plaintiff is referring to.” (Response at 39).

As it does not appear from plaintiff’s Motion, defendant’s Opposition, or plaintiff’s Response, that plaintiff included Exhibit C in his Request for Admission, and thus whether defendant could reasonably be expected to identify the document as referred to by plaintiff, the Court agrees with Florin, and no further response to this Request is required.

D. Requests for Defendant Pamela Lux

Request for Production No. 1 - granted

Defendant Lux objects to Request No. 1 (Set 1) on several grounds, and asserts that the “requested information is not in the custody or control” of Lux. (Motion, Ex. 15 at 2). Plaintiff, in his Response, writes that defendant Lux, “as a supervising doctor” at ARMC, is “legally entitled to access” the requested documents,[7] and finally that defendant Lux’s “attorneys are in possession of the documents the plaintiff has requested[,] and therefore [defendant] Lux has access, custody, and control of the pertinent documents.” (Response at 41).

The Court agrees with plaintiff that Lux appears to be in possession, custody, or control of the requested documents. See Fed.R.Civ.P. 34(a)(1); see also In re Bankers Trust Co., 61 F.3d 465, 469 (6th Cir. 1995) (“[F]ederal courts have consistently held that documents are deemed to be within the ‘possession, custody or control’ for purposes of Rule 34 if the party has actual possession, custody or control, or has the legal right to obtain the documents on demand.”) (citation omitted). “A party may be ordered to produce a document in the possession of a non-party entity if that party has a legal right to obtain the document or has control over the entity who is in possession of the document.” Soto v. City of Concord, 162 F.R.D. 603, 619 (N.D. Cal. 1995). Accordingly, Lux is ordered to provide the requested documents.

Request for Production No. 3 - granted in part

In his Request No. 3 (Set 1), plaintiff requests “copies of any lawsuits tort claims [sic], and or vicil [sic] rights actions, staff complaints etc... filed against doctor Pamela Lux for failure to properly supervise subordinate ARMC medical staff from [five] years prior to the incident on [November 17, 2010,] to the present.” (Motion, Ex. 15 at 3).

The Request is granted, but limited to the extent that Lux must produce documents related to any such legal action that resulted in a judgment against her, or a complaint against her being found to be true, during the two years prior to November 17, 2010, and for two years after that date. If there is no record of any such legal action or complaints within that time period, Lux must provide a declaration so stating.

Request for Production No. 6 - granted in part

In his Request No. 6 (Set 2), plaintiff requests “any kind of work performance evaluations for [ ] defendant Pamela Lux from five years prior to the incident on [November 18, 2010,] to the present.” (Motion, Ex. 18 at 1). Defendant is ordered to provide the requested documents, but only for the period of time beginning two years prior to November 17, 2010, and ending two years after that date, and only with regard to records containing findings or conclusions that Lux was indifferent to the medical needs of patients, or otherwise performed in a deficient manner with regard to her supervisory duties. If no such records exist, Lux shall so state in a declaration.

Interrogatory No. 10 - granted in part

*8 In Interrogatory No. 10 (Set 2), plaintiff requests to “know the names addresses and telephone numbers of the following to [sic] ARMC employees who had interaction with him on the night of [November 17, 2010,] into the morning of [November 18, 2010], [sic] the male nurse orderly or x-ray technician that took him to x-ray at 0110 hours on the morning of [November 18, 2010,] and the nurse who filled out the ARMC emergency department progress notes with the initials MT, MA, or Mg at 0210 hours, 0128 and 0250 hours.” (Motion, Ex. 16 at 3).

Lux objects on the grounds, among others, that the Interrogatory is “[v]ague and ambiguous, argumentative as to ‘interaction with him,’ calls for speculation, [and] lacks foundation.” (Motion, Ex. 16 at 3). In her Opposition, Lux asserts that she “does not know what [plaintiff] means by ‘interacted’ with him,” and that the Interrogatory thus calls for speculation. (Opposition at 11).

To the extent plaintiff’s Interrogatory involves any investigation into who, if anyone, “interacted” with plaintiff, the Court agrees with defendant that it is vague and ambiguous. However, the Court finds that, to the extent plaintiff has described individuals by their specific functions on the particular dates and times indicated -- e.g., the “male nurse orderly or x-ray technician” who brought plaintiff to “x-ray at 0110 hours” on November 18, 2010, and the nurse whose initials begin with the letter “M” and who filled out the ARMC emergency department progress notes -- the Interrogatory is not vague or ambiguous. (See Motion, Ex. 16 at 3). Accordingly, plaintiff’s Interrogatory is granted, in part, to the extent that Lux is ordered to provide a further response, limited to those individuals specifically described by their function in the Interrogatory, to the extent Lux is able to determine their identities.

Interrogatory No. 11 - granted in part

In Interrogatory No. 11 (Set 2), plaintiff requests the “names, addresses, telephone numbers of all the witnesses for the defendants in this immediate action case # ED CV11-20490[-DDP] (PLA) [sic].” (Motion, Ex. 16 at 3). Lux objects on the grounds that the Interrogatory is vague and ambiguous, argumentative as to the terms “all the witnesses for the defendants” and “in this immediate action,” and calls for speculation. (Motion, Ex. 16 at 4). In the Opposition, Lux asserts that she “is under no obligation to conduct an investigation for the purpose of determining who all the ‘witnesses’ plaintiff might be talking about are.” (Opposition at 11).

The Court does not find plaintiff’s Interrogatory to be vague and ambiguous, argumentative, or to call for speculation. Plaintiff identifies “this action” by its docket number in this Court, and specifies that the “witnesses” to whom he refers are those known by defendant Lux to be the witnesses that defendant will call in this action. (See Motion, Ex. 16 at 3). Lux’s objections are overruled, and plaintiff’s Interrogatory is granted, in part, to the extent Lux is ordered to provide the work contact information for the witnesses she intends to call in this action. SeeJohnson v. Thompson, 971 F.2d 1487, 1497 (10th Cir. 1992) (citing Lukaszewicz v. Ortho Pharm. Corp., 90 F.R.D. 708, 709 (E.D. Wis. 1981) ); Ragge, 165 F.R.D. at 604-05 (requiring a balance of a party’s right to privacy against the importance of the information to the case).

Interrogatory No. 13 - granted

Lux objects to Interrogatory No. 13 (Set 3) on the grounds, among others, that the Interrogatory is argumentative and vague and ambiguous. (Motion, Ex. 17 at 1-2). The Court disagrees, but to the extent it is phrased inartfully, defendant must provide a response to the Interrogatory phrased as follows: “Is it defendant’s contention that, prior to clearing a patient for release to home or jail, ARMC’s policies, procedures, customs and/or practices require a supervising physician to review that patient’s triage assessment, progress notes, and medical chart as filled out during the patient’s treatment? If the answer is ‘no,’ please explain.”

Interrogatory No. 16 - granted

*9 In Interrogatory No. 16 (Set 3), plaintiff asks defendant Lux whether it is her contention that “on the morning of [November 18, 2010,] [ ] you were not the supervising doctor and/or physician of defendant Joseph Florin in the [ ]ARMC[ ] emergency room.” (Motion, Ex. 17 at 3). Defendant Lux objects on the grounds, among others, that the Interrogatory is ambiguous and argumentative as to the term “supervising doctor.” (Id.).

To the extent Lux objects to plaintiff’s use of the term “supervising doctor,” the issue of Dr. Lux’s role as a supervising physician was addressed in the Court’s February Order. (See February Order at 10, n. 5). Lux’s remaining objections are overruled and Lux must respond to this Interrogatory.

CONCLUSION

Plaintiff’s Motion to Compel (Docket No. 108) is granted in part and denied in part as set forth above. No later than April 23, 2014, defendants WVDC, Joseph Florin and Pamela Lux shall produce all documents and interrogatory responses as detailed above. To the extent any of these defendants withholds any documents or information based on a claim of privilege, a detailed privilege log containing each withheld document must be provided along with its production. See The Rutter Group, California Practice Guide, Federal Civil Procedure Before Trial, Form 11:A (Privilege Log). All responses must be verified pursuant to Fed.R.Civ.P. 33(b)(3). To the extent defendants seek to produce any documents or information pursuant to a protective order, defendants may submit a draft protective order for the Court’s consideration no later than April 16, 2014.

The Court sua sponte extends the time for plaintiff to file his opposition to defendants’ summary judgment motion to no later than May 7, 2014. Defendants’ reply is due no later than June 6, 2014.

It is so ordered.

In her Responses to Interrogatories (Sets 2 and 3), and Responses to Requests for Production (Set 2), Lux has renumbered the responses, indicating in parentheses the numbering by which plaintiff labeled each discovery request. (See, e.g., Motion, Ex. 16 at 2). The Court utilizes plaintiff’s numbering for purposes of this Order.

In addition to a December 2, 2013, Proof of Service (Motion, Ex. 2), plaintiff includes two additional proofs of service for a subsequent subpoena on December 30, 2013, and a letter of meet and confer on January 12, 2014, and indicates that he “received no response” to either. (See Motion at 3-4; Motion, Ex. 4, 5). Plaintiff states that he sent a “third subpoena which was a duplicate of the second” via “certified mail” to ARMC and “County Counsel” on January 27, 2014. (See Motion at 3-4; Motion, Ex. 6).

Although WVDC indicates in its Opposition that it “does not have a[n] [October 18, 2010] request,” the Court observes that, in its opposition to Interrogatory No. 18, defendant wrote that “the only request defendant has with the language cited by plaintiff contains a date of [October 18, 2010].” (Compare Opposition at 5 with Opposition at 4).

In his Response, plaintiff addresses this error, writing that he “was suffering from severe chest pain when breathing when he wrote the [Health Services Request Form (“Request Form”),] and mistakenly wrote the wrong month.” He asserts that other markings on the Request Form, included as Exhibit 5 in his Response, confirm that the Request Form was actually submitted in November. (Response at 10-11; see also Response at 13-14, 19-22; Response, Ex. 5).

Plaintiff includes, as Exhibits 13 and 14 to his Response, the exhibits labeled “9” and “10” in his Request. (See Response at 34; Response Exs. 13, 14).

Plaintiff includes, as Exhibits 15 and 16 to his Response, the exhibits labeled “11” and “12” in his Request. (See Response at 34; Response Exs. 13, 14).

Plaintiff cites “Medical Staff Rules and Regulations Table of Contents,” which states that “[a] procedure manual [is] available for staff use.” (Response at 41; Response, Exhibit 12).