*1 This matter is before the Court on Defendants Lindsey Middlecamp's, Grace Miller's, and Catherine Schaefer's respective Motions to Compel Discovery, to Compel Attendance at a Deposition, and for Entry of a Protective Order [Doc. No. 90 in Case No. 17-cv-3058 (hereafter “Middlecamp”; Doc. No. 81 in Case No. 18-cv-466 (hereafter “Miller/Schaefer”) ].[1] For the reasons set forth below, the motions are granted in part, denied in part, and denied without prejudice in part, and the hearing noticed for these motions on November 18, 2019, is canceled.

I. PROCEDURAL HISTORY

Plaintiff Brock Fredin, appearing pro se, has sued Defendants Lindsey Middlecamp, Grace Miller, and Catherine Schaefer (collectively, “Defendants”) in the above-captioned actions. The underlying allegations and the specific remaining claims are described at length in the Orders of the Honorable Susan Richard Nelson, United States District Judge, together with the underlying Reports and Recommendations, on Defendants’ motions to dismiss in these cases. [Doc. Nos. 30 & 39 in Middlecamp; Doc. Nos. 38 & 49 in Miller/Schaefer.]

Following resolution of Defendants’ motions to dismiss, the Court established essentially identical Pretrial Scheduling Orders in the two cases, providing in pertinent part that fact discovery “must be commenced in time to be completed on or before September 30, 2019.” [Doc. No. 69 at 5 in Middlecamp; Doc. No. 64 at 5 in Miller/Schaefer (emphases in originals).] Because the Federal Rules of Civil Procedure allow 30 days for a party to provide written responses to discovery requests (see Fed. R. Civ. P. 33(b)(2) and 34(b)(2)), this meant that any interrogatories or document requests would have had to be served, at the latest, by August 31, 2019, in order to be timely under the Pretrial Scheduling Order.

On August 30, 2019,[2] Defendants served interrogatories and document requests on Fredin in both actions. (Ballinger Decl. ¶¶ 2, 3 [Doc. No. 94]; Ex. A [Doc. No. 94-1]; Ex. B at 3 [Doc. No. 94-2].) Fredin, meanwhile, had served no interrogatories or document requests on Defendants.[3] At some point in late September, Fredin served responses and objections to Defendants’ discovery.[4] (Ballinger Decl. ¶¶ 4, 5; Ex. C [Doc. No. 94-3]; Ex. D [Doc. No. 94-4].)

*2 Defendants also served on August 30 a notice that they intended to take Fredin's deposition in both cases on September 30, 2019, at the offices of Defendants’ counsel in Minneapolis. (Ballinger Decl. ¶¶ 2, 3; Ex. A; Ex. B at 3.) On September 12, Fredin emailed counsel to ask if the deposition could instead be held on September 23 because of conflicts with his work schedule. (Ballinger Decl. Ex. B at 2.) He also expressed concern at having the deposition held at counsel's offices in downtown Minneapolis and proposed either conducting the deposition by remote videoconference or that it be held at a courthouse. (Id.) Defendants’ counsel indicated they would be willing to move the deposition date, but would not be willing to conduct the deposition before receiving Fredin's discovery responses (which, pursuant to Federal Rule of Civil Procedure 33(b)(2), were not due until September 30). (Id.) Fredin emailed counsel again on September 27 stating that he did not intend to appear for the deposition noticed for September 30. (Breyer Aff. Ex. K at 23 [Doc. No. 88-11].)

Defendants contend Fredin's responses were deficient, which in turn has hindered efforts to reschedule Fredin's deposition. Accordingly, they seek an order compelling Fredin to respond in full to the written discovery and an order that he make himself available for a deposition at the office of Defendants’ counsel within twenty days after producing any additional documents and information the Court may order.

Defendants also ask that the Court enter a protective order governing the treatment of confidential information produced by either party in the case. Finally, Defendants seek sanctions under Federal Rule of Civil Procedure 37(a)(5)(A) in the form of an award of attorneys’ fees and costs in connection with the instant motion.

II. DISCUSSION

A. Fredin's Responses to Defendants’ Written Discovery in the Miller/Schaefer Case

1. Interrogatories Nos. 1 and 10

Interrogatory No. 1 seeks “all online profiles, identities, usernames, or other identifiers” that Fredin has used. (Ballinger Decl. Ex. A at 18.) Interrogatory No. 10 asks Fredin to identify “all addresses where you have resided from 2016 to present, indicating the dates in which you have lived at those locations.” (Id. at 19.) Fredin did not provide information in response to either interrogatory, nor did he interpose specific objections to this interrogatory. Instead, in response to each of these two interrogatories he “state[d]” or “incorporate[d] the foregoing General Objections,” a reference to a paragraph at the beginning of his responses headed “Plaintiff Brock Fredin's General Objections.” (Ballinger Decl. Ex. D at 2, 3, 9.) In that paragraph, in addition to echoing the complaints about Defendants’ conduct that are alleged in his Amended Complaint (which are not in and of themselves valid objections to discovery requests), Fredin quoted from Federal Rule of Civil Procedure 26(b)(1), which describes the permissible scope of discovery in civil litigation.[5] The paragraph went on to state that “each and every question put forth [is] violative” of that rule. (Ballinger Decl. Ex. D at 2.)

But the so-called “General Objections” are ineffective to preserve any legitimate objections to these interrogatories. Federal Rule of Civil Procedure 33(b)(4) states that “the grounds for objecting to an interrogatory must be stated with specificity.” Courts have routinely rejected “general objections” to interrogatories, holding that any objection not explicitly set forth in response to the particular interrogatory is deemed waived. See, e.g., Murphy by Murphy v. Piper, No. 16-cv-2623 (DWF/BRT), 2018 WL 2278107, at *6 (D. Minn. May 18, 2018); Dukes v. Specialty Staff Inc., No. 07-cv-2587 (ADM/JSM), 2008 WL 11456262, at *5 (D. Minn. Apr. 14, 2008). But more importantly, even if Fredin had replicated his quote from Rule 26(b)(1) in each of his responses to Interrogatories Nos. 1 and 10, it still did not “state with specificity” the grounds for his objection. He did not specify what it was about the interrogatory that he believed called for nondiscoverable information, or on what ground. He did not state whether he thought the information was irrelevant, or simply too burdensome to produce, or whether he believed that it exceeded the permissible bounds of discovery in some other particular respect. Thus, his generalized reference to Rule 26(b)(1) was not sufficient to preserve his objection, and the Court can compel him to respond completely to both interrogatories on this ground alone.

*3 Furthermore, even if (as appears from Fredin's memorandum in response to this motion) his real objection was that the information sought was not relevant (see Pl.’s Mem. Opp'n at 11), the Court disagrees. As to Interrogatory No. 1, as Defendants point out, Fredin claims that Defendants or others acted under online aliases to damage him. That makes identification of his own online identifiers highly relevant. As to Interrogatory No. 10, Defendants argue there is some doubt as to whether diversity jurisdiction is proper in this case, and that Fredin's residences during the relevant time period are relevant. Fredin disagrees with Defendants’ view on diversity, but the only question at this juncture is whether information about his place of residence could be relevant to resolving that issue. Accordingly, the Court finds this interrogatory seeks relevant information as well. Furthermore, neither interrogatory is patently overly broad nor does Fredin claim it would be unduly burdensome to provide the requested information.

Accordingly, the Court will order Fredin to answer, fully and completely, Interrogatories Nos. 1 and 10 within 21 days of the date of this Order.

2. Document Requests Nos. 1-7, 9, 13, 15, 16, and 17

Defendants Miller and Schaefer contend Fredin failed to provide adequate responses to Document Requests Nos. 1-9, 13, 15, 16, 17, and 19. In response to all of these requests but Nos. 8 and 19 (which the Court will address separately), Fredin's responses state no objections to the requests,[6] but state simply that the documents responsive to those requests are “Included.” Fredin does not, however, say what body of documents they were included in, when those documents were produced, or where the documents responsive to any particular request can be found within that body of documents. (See Ballinger Decl. Ex. D at 15.)

While Fredin complains generally in his memorandum in opposition that Defendants’ document requests were unduly burdensome and harassing and/or sought irrelevant information, he made no such specific objections within his responses to Requests Nos. 1–7, 9, 13, 15, 16, or 17. Federal Rule of Civil Procedure 34(b)(2)(B) provides that “[f]or each item or category, the response must either state that inspection and related activities will be permitted as requested or state with specificity the grounds for objecting to the request, including the reasons.” (Emphasis added.) As Fredin made no such specific objections in his responses to the above requests, let alone indicated whether and to what extent he was withholding documents responsive to those requests on the basis of such objections (as required by Rule 34(b)(2)(B)), any such objections were waived, and the Court will not consider any post hoc arguments in his opposition memorandum regarding the relevance or burdensomeness of these requests. See Cardenas v. Dorel Juvenile Grp., Inc., 230 F.R.D. 611, 621 (D. Kan. 2005). Accordingly, Fredin is obligated to provide all documents in his possession, custody, or control responsive to these requests.

It is impossible to tell from either side's characterizations or statements in their legal memoranda, or from the documents of record before the Court, whether Fredin has complied with that obligation, however. Defendants contend Fredin produced no documents responsive to a number of these requests (e.g., Requests Nos. 1, 2, 3, 7, 9, 13, 15, 16, and 17) and that he produced some but not all documents in his possession in response to others (e.g., Requests Nos. 4, 5). Defendants also note that Fredin's production, albeit “limited,” was “seriously disorganized,” making it difficult to discern whether documents responsive to some requests were or were not “included.” (Defs.’ Mem. Supp. at 3.) Fredin, on the other hand, insists that he has “provided hundreds or thousands of documents provided in a zip folder” (Pl.’s Mem. Opp'n at 9) and that the production was “seriously organized” (id. at 7), and he describes as “bold-faced lies” Defendants’ claims that he did not produce responsive documents (id. at 7, 9).

*4 There is no indication, however, that Fredin's production complied with Rule 34(b)(2)(E)(i), i.e., that he either produced the documents organized as he keeps them in the usual course of business, or that he organized and labeled them to correspond to the requests. Because the Court has no intention of getting into an endless round of arguments with the parties about how Fredin keeps documents in the ordinary course of business and whether and to what extent his production reflected that, the Court will order Fredin within 21 days of the date of this Order to either (1) re-produce all of the documents responsive to Defendants Miller and Schaefer's requests in a form that is organized and labeled to directly refer to and correspond with the requests, or (2) prepare and produce a log clearly identifying each of the documents he has already produced to Defendants, and as to each such document identify the specific request or requests to which it responds. With that information, Defendants should be able to discern what documents Fredin intended to respond to what requests, as well as whether there are obvious gaps in the production. By way of example only, Request No. 2 seeks copies of the specific messages identified in paragraph 16 of Fredin's Amended Complaint against Miller and Schaefer. Therefore, Fredin must identify for Defendants which specific documents in his production are the thirty messages to which he was referring in that paragraph of his Amended Complaint.

Furthermore, to the extent Fredin has documents in his possession, custody, or control that are responsive to Requests Nos. 1-7, 9, 13, 15, 16, or 17, that he has failed to produce to Defendants, regardless of the reason, he is ordered to produce all such documents within 21 days of this Order, organized and labeled to correspond with the requests. If he has no additional documents responsive to any of those requests, he must serve a supplemental response stating that he has searched for and has no additional responsive documents.

Request No. 15 requires some additional comment, however. This request calls for Fredin's “curriculum vitae, resume, or other document describing [his] professional credentials.” (Ballinger Decl. Ex. A at 22.) Fredin notes in his responsive memorandum that he provided copies of emails that included his resume and that his resume can also be found online at his LinkedIn page. He seems to be concerned that he may have an obligation to continuously update his resume for Defendants’ benefit. (Pl.’s Mem. Opp'n at 9.) Fredin's obligation is to produce a copy of the most complete and up-to-date resume or curriculum vitae he has in his possession or has posted online. He does not have an obligation to update it continually for Defendants’ benefit, although Defendants are certainly entitled to inquire at his deposition about his employment history, including any employment he may have obtained subsequent to his last updating of his resume.

If after receipt and review of the materials ordered herein, Defendants can make a specific showing as to why they still believe Fredin has responsive information in his possession, custody, or control, but has failed to produce it, they may move for further relief. The Court also reminds Fredin that it is extremely likely that he would not be allowed later to use or rely upon anything covered by these requests that he did not produce in discovery.

3. Request No. 8

Request No. 8 seeks “all documents that constitute, refer, or relate to medical evaluations of Plaintiff's emotional distress.” (Ballinger Decl. Ex. A at 22.) Fredin objected in his response to that request that it was “burdensome.” (Ballinger Decl. Ex. D at 15.) In his response to Defendants’ motion, he elaborated that he has provided the names and addresses of any clinics,[7] and that Defendants “can subpoena such information if they choose.” (Pl.’s Mem. Opp'n at 8.) He goes on to state that he is “willing to undergo a psychological exam” at Defendants’ expense. (Id.)

Because fact discovery is over, it is too late for Defendants to seek an independent medical examination under Federal Rule of Civil Procedure 35, and it is also too late for Defendants to serve subpoenas on clinics identified by Fredin in his discovery responses. That is not Fredin's fault; Defendants could have sought discovery earlier regarding the names of the health care providers Fredin has seen so that they could then obtain releases and subpoena the information directly from those clinics. Moreover, they could have, if they wanted, requested (and paid for) a Rule 35 medical examination.

*5 So the only issue before the Court is whether Fredin's objection that Request No. 8 was “burdensome” raises a legitimate objection to the request.[8] It is unclear what burden Fredin is referring to. If he is concerned that the request requires him to request copies of medical evaluations from his health care providers in order to produce them to Defendants, the Court does not believe (and Defendants have not argued) that he has any obligation to do so.[9] On the other hand, if he already has copies of any such evaluations in his possession, the Court does not see how it would be burdensome to find and produce them.

Accordingly, the Court overrules Fredin's objection that Request No. 8 is burdensome. Fredin is ordered to produce within 21 days copies of any documents in his possession that constitute, refer, or relate to medical evaluations of his emotional distress, organized and labeled to indicate which documents are responsive to this request. If he has no additional documents responsive to this request, he must serve a supplemental response stating that he has searched for and has no additional responsive documents.

4. Request No. 19

Request No. 19 demands that Fredin “produce for examination by an independent computer forensic firm all electronics (phone, tablet, iPad, laptop, desktop, flash drive or other device) used to post, submit, respond or otherwise communicate with the online sites and persons identified in the Amended Complaint.” (Ballinger Decl. Ex. A at 23.) Fredin objects that the request is “inflammatory.” (Ballinger Decl. Ex. D at 15.) The Court does not find it “inflammatory,” but it is almost certainly overly broad and disproportionate to the needs of the case.

The Court need not resolve the motion as to that request on those grounds, however. Rather, the Court denies the request as untimely. The Pretrial Scheduling Order required that discovery be commenced in time to be completed by September 30, 2019. Defendants served their requests for production on Fredin on August 30. Therefore, Fredin's written responses to Defendants’ requests were not due until September 30. Furthermore, Rule 34 does not require the responding party to provide the things sought in the requests within 30 days, only that it provide the written responses within that time, and that the written responses identify a reasonable time when the things sought will be produced. See Fed. R. Civ. P. 34(b)(2)(A) and (B). In no universe could Defendants reasonably have expected that even if Fredin were otherwise willing to produce all of his electronic devices for a forensic examination (and they cannot have imagined such a request would not draw an objection), such production would be made bright and early on September 30, a reasonable protocol for their examination and review negotiated, the examinations conducted and completed, the devices returned to Fredin, the results produced, his review of those results for irrelevant or other nondiscoverable information completed, and the relevant and discoverable information culled and produced to Defendants, all in the same day. In other words, if Defendants wanted to conduct a forensic examination of Fredin's devices, they needed to have begun that process long before 30 days prior to the close of fact discovery. Accordingly, the Court denies Defendants’ motion as to that request.

B. Fredin's Responses to Defendants’ Written Discovery in the Middlecamp Case

1. Interrogatories 7 and 14

*6 Middlecamp's Interrogatory No. 7 sought the same address information requested in Miller and Schaefer's Interrogatory No. 1. (Ballinger Decl. Ex. A at 7.) Fredin made the same response, incorporating by reference the same paragraph of “General Objections.” (Ballinger Decl. Ex. C at 4.) For the same reasons described above, the Court will order Fredin to answer Middlecamp's Interrogatory No. 7 fully and completely.

Interrogatory No. 14 asks Fredin to “identify any oral representations, admissions, or statements against interest allegedly made by Defendant that are relevant to the issues in this lawsuit.” (Ballinger Decl. Ex. C at 4.) Once again, Fredin responded solely by incorporating the “General Objections.” Once again, that paragraph is ineffective to preserve any legitimate objection he may have had to the interrogatory. Furthermore, Middlecamp is clearly entitled to seek identification of each such oral representation, admission, or statement against interest that Fredin claims Middlecamp made that is relevant to any issue in this lawsuit. Accordingly, Fredin must answer this interrogatory fully and completely by identifying each such oral representation, admission, or statement against interest in accordance with the instructions provided by Defendants in paragraphs 5 and 6 of their Interrogatories to Middlecamp (Ballinger Decl. Ex. C at 3–4). For any written admission or statement against interest, Fredin may, in the alternative, produce copies of the documents themselves pursuant to Rule 33(d), so long as his answer to the interrogatory states that he is doing so and he clearly identifies which documents are responsive to this interrogatory.[10]

2. Requests Nos. 3, 5, and 13

As in his responses to Miller and Schaefer's document requests, Fredin responded to Middlecamp's Requests Nos. 3, 5, and 13 simply with the word “Included.” And, as with his responses to Miller and Schaefer's requests, it is impossible to tell whether in fact he produced none, some, or all of the requested documents in his possession, custody, and control. Accordingly, the Court will order Fredin to, within 21 days of the date of this Order, either (1) re-produce all of the documents responsive to Middlecamp's document requests in a form that is organized and labeled to directly refer to and correspond with the requests, or (2) prepare and produce a log clearly identifying each of the documents he has already produced to Defendants, and as to each such document identify the specific request or requests to which it responds.

Furthermore, to the extent Fredin has documents in his possession, custody, or control that are responsive to Requests Nos. 3, 5, or 13, that he has failed to produce to Defendants, regardless of the reason, he is ordered to produce all such documents within 21 days of this Order, organized and labeled to correspond with the requests. If he has no additional documents responsive to any of those requests, he must serve a supplemental response stating that he has searched for and has no additional responsive documents.

If after receipt and review of the materials ordered herein, Defendants can make a specific showing as to why they still believe Fredin has responsive information in his possession, custody, or control, but has failed to produce it, they may move for further relief. The Court again reminds Fredin that it is extremely likely he would not be allowed later to use or rely on anything covered by these requests that he did not produce in discovery.

3. Request No. 4

*7 Middlecamp's Request No. 4 is identical to Miller and Schaefer's Request No. 8, seeking “all documents that constitute, refer, or relate to medical evaluations of Plaintiff's emotional distress.” (Ballinger Decl. Ex. A at 10.) Similarly, Fredin objected in his response to this request that it was “burdensome.” (Ballinger Decl. Ex. C at 9.) For the same reasons described above, Fredin is ordered to produce within 21 days copies of any documents in his possession that constitute, refer, or relate to medical evaluations of his emotional distress, organized and labeled to indicate which documents are responsive to this request. If he has no documents responsive to this request, he must serve a supplemental response stating that he has searched for and has no responsive documents.

4. Request Nos. 11 and 12

Request No. 11 seeks Fredin's curriculum vitae, resume, or similar document that describes his professional background (Ballinger Decl. Ex. A at 11), and is the same as Miller and Schaefer's Request No. 15, which was discussed above. Fredin's response to this request was “Unknown” (Ballinger Decl. Ex. C at 9), but he acknowledges in his memorandum in opposition to this motion that this was an error. He states that he provided his resume in his document production and also points to various places online where his resume is posted (Pl.’s Mem. Opp'n at 13). The Court's order with regard to this request is the same as its order on Miller and Schaefer's Request No. 15.

Request No. 12 seeks “[a]ll documents that constitute, refer, or relate to communications, including electronic communications, exchanged between you and any person concerning the issues/matters identified in the pleadings.” (Ballinger Decl. Ex. A at 11.) Oddly, Fredin's response to this request was “Unknown” (Ballinger Decl. Ex. C at 9), and his memorandum in opposition says nothing further on the subject. (Pl.’s Mem. Opp'n at 13). Accordingly, the Court orders Fredin to respond in full to this request within 21 days of the date of this Order and that his production be organized and labeled to indicate which documents are responsive to this request. If he has no additional documents responsive to this request, he must serve a supplemental response stating that he has searched for and has no additional responsive documents.

5. Request No. 15

Middlecamp's Request No. 15 is identical to Miller and Schaefer's Request No. 19. Her motion to compel Fredin to respond to this request is denied for the same reasons.

C. Fredin's Deposition

It is not necessary for purposes of this Order to go into detail about the discussions between the parties regarding the date, time, and location of Fredin's deposition. Defendants have made it clear, not unreasonably so, that they need Fredin's documents and full interrogatory responses before they take the deposition, and Fredin agrees they are entitled to take his deposition. The only real dispute between the parties has to do with the location. Fredin has asked that his deposition be taken at a location other than in the offices of Defendants’ counsel in downtown Minneapolis. While the Court recognizes that in view of Fredin's current residence in Milwaukee, Wisconsin, and work situation, downtown Minneapolis may not be the most convenient for him, the fact remains that he brought these cases in federal court in the District of Minnesota. Barring truly exigent circumstances, none of which are present here, Defendants have the right to take his deposition in this District. Furthermore, it is commonplace that such depositions be taken in counsel's offices, and since Fredin is unrepresented, that leaves the offices of Defendants’ counsel. Furthermore, they have agreed to validate Fredin's parking in the ramp associated with their building. Accordingly, the Court orders that Fredin will make himself available for a deposition of not more than seven hours (see Pretrial Scheduling Order at 6 [Doc. No. 69 in No. 17-cv-3058] no later than 21 days after he completes his production of the documents and information required by this Order. The Court expects both Defendants’ counsel and Fredin to work together in good faith to find a date for the deposition that will work for both sides. If they cannot, the Court may set a date arbitrarily without regard to whether it will work for any party.

D. Defendants’ Request for a Protective Order

*8 Defendants initially proposed to Fredin that a protective order be entered that not only addressed the handling of confidential information produced in discovery but also contained a provision barring Fredin from personally taking or attending the depositions of any of the Defendants, on the ground that there are harassment restraining orders against him and in favor of each of the Defendants. (Ballinger Decl. ¶ 7; Ex. F [Doc. No. 94-6.) Not surprisingly, Fredin objected to the inclusion of that provision in any protective order. In the meantime, however, the deadline for completing fact discovery expired without Fredin having noticed Defendants’ depositions, and the Court has denied his motion to extend discovery. [Doc. No. 89 in No. 18-cv-3058; Doc. No. 80 in No. 18-cv-466.] Accordingly, as matters now stand, Fredin will not be able to notice the depositions of Defendants in any event, and therefore, as Defendants acknowledged in the instant motion, that provision of their proposed protective order is unnecessary. (Defs.’ Mem. Supp. at 13.) Fredin has not expressed any cogent objection to the remainder of the proposed protective order, which is based on the District's model order. See https://www.mnd.uscourts.gov/FORMS/court_forms.shtml. Accordingly, the Court will grant Defendants’ motion and will enter a Protective Order in the form requested, excluding the paragraph addressing attendance at Defendants’ depositions because that issue is moot and that paragraph therefore unnecessary.

E. Defendants’ Request for Attorneys’ Fees and Sanctions

Defendants seek fees and sanctions pursuant to Federal Rule of Civil Procedure 37(a)(5)(A), arguing that Fredin's conduct was unreasonable, unjustified, and necessitated the bringing of the motion. It is true that Fredin's responses were inadequate in a number of respects, but as the Court has already noted, the Court cannot determine from the record currently before it whether in fact Fredin failed to produce documents in his possession, custody, or control that he should have produced or whether his production was simply organized in such a way that made it impossible to tell. Moreover, there was no true dispute about the deposition other than the location, and the Court has denied outright Defendants’ demand that Fredin turn over all of his electronic devices. Accordingly, the Court denies without prejudice Defendants’ motion for sanctions. If Fredin fails to comply with this Order, and/or it is clear from his production that it remains deficient or that his prior conduct in responding was indeed egregious and unjustified, Defendants may file a new motion for sanctions under either Rule 37(a)(5)(A) or Rule 37(b)(2), as applicable, citing specific evidence of that conduct and the claimed deficiencies. If such a motion is brought, the Court will consider it along with any evidence submitted by Fredin, including evidence regarding the exceptions set forth in Rule 37(a)(5)(A)(i)-(iii).

Accordingly, IT IS HEREBY ORDERED that:

Because Middlecamp's motion and supporting papers are identical to those filed by Miller and Schaefer, for the sake of convenience and efficiency the Court will cite only Middlecamp's filings in the discussion herein. Citations to specific pages refer to the CM/ECF pagination.

Defendants’ supporting memorandum states that the discovery requests were served on August 29, 2019 [Doc. No. 92 at 1]; however, the Ballinger Declaration does not state the date on which they were served, and the cover email to which the requests were attached is dated August 30, 2019 (Ballinger Decl. ¶ 2 [Doc. No. 94]; Ex. B at 3 [Doc. No. 94-2] ).

Fredin's subsequent attempts to seek discovery are described in the Court's Order on Fredin's Motion to Extend Fact Discovery [Doc. No. 89 in Middlecamp].

Defendants variously describe Fredin's responses as having been served on September 29 (Defs.’ Mem. Supp. at 11) and “on September 30, 2019, at 11:50 p.m.” (Defs.’ Mem. Supp. at 2). No certificate of service (if one exists) was included in Defendants’ exhibits to this motion; Fredin's memorandum in opposition [Doc. No. 96] does not state when he served his responses; and it is impossible to tell from the responses themselves when they were served. (See Breyer Aff. Ex. F [Doc. No. 88-6]; Ex. G [Doc. No. 88-7]; Ballinger Decl. Ex. C; Ex. D.) However, since Defendants do not contend the responses were late, but only deficient, the actual date of service appears to be irrelevant.

Unless otherwise limited by court order, the scope of discovery is as follows:

The Court cannot tell for certain whether Fredin intended that his paragraph of “General Objections” at the beginning of the document was intended to apply to his responses to the document requests as well. Regardless, for the reasons already discussed, such “general objections” are ineffective. Courts have widely held that so-called “general objections” do not comply with the specificity requirements of Rule 34(b)(2)(B) and are deemed waived. See, e.g., Arctic Cat v. Polaris Indus. Inc., No. 13-cv-3579 (JRT/FLN), 2015 WL 12830409, at *2 (D. Minn. June 2, 2015); Cargill, Inc. v. Ron Burge Trucking, Inc., 284 F.R.D. 421, 424 (D. Minn. 2012).

This appears to be a reference to his response to Interrogatory No. 5. (See Ballinger Decl. Ex. D at 6-7.)

Plaintiff does not dispute that he has put his medical condition in issue through his claim that Defendants’ alleged conduct caused him emotional distress. He does not contend, either in his response to the request nor in his response to this motion, that the request is objectionable on the ground that it seeks information covered by the doctor/patient privilege.

The Court warns Fredin, however, that he cannot later obtain responsive documents from his health care providers and expect to be allowed to use them affirmatively in support of his case if he refused to do so in timely response to Defendants’ discovery requests.

To the extent Middlecamp's document requests seek copies of any such admissions or statements against interest, see, e.g., Request No. 14 (Ballinger Decl. Ex. A at 9), such documents would have to be produced in any event.