*1 This cause came on for consideration without oral argument on the following motion filed herein:

I. BACKGROUND.

On July 5, 2018, Plaintiff filed a complaint against Defendant Rollins College, alleging violations of Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq., as well as a state-law breach of contract claim. Doc. No. 1. In his amended complaint, Plaintiff alleges that while he was a student at Rollins College, he was falsely accused of sexual misconduct by another Rollins student (“Jane Roe”). Doc. No. 14, at 3. Defendant investigated Ms. Roe's claims and concluded that Plaintiff had violated the school's Sexual Misconduct Policy. Id. at 26. Plaintiff alleges that the hearing and appeal process administered by Defendant resulted in an erroneous outcome based on the flawed and biased proceedings employed; Defendant committed gender bias and discrimination in the investigation and adjudication of Ms. Roe's allegations; and Defendant selectively enforces its sexual assault policies on the basis of gender. Id. at 36.

In the instant motion, Defendant seeks to compel Plaintiff to provide full and complete responses to its first set of interrogatories and to produce documents responsive to its first request for production. Doc. No. 40. Specifically, Defendant seeks responses to Interrogatories 5, 6, and 7, as well as documents responsive to Requests 3 and 9. Id. Plaintiff has filed a response to the motion. Doc. No. 41. Accordingly, the matter is ripe for review.

II. APPLICABLE LAW.

Under the Federal Rules of Civil Procedure, discovery is permitted to obtain “any nonprivileged matter that is relevant to any party's claim or defense.” Fed. R. Civ. P. 26(b)(1). The party requesting discovery has the burden of demonstrating the relevance of the discovery requests. See Stern v. O'Quinn, 253 F.R.D. 663, 670 (S.D. Fla. 2008). When the discovery requests seek relevant information, the responding party has the burden of showing that the discovery is improper, unreasonable, or burdensome. The responding party “must show specifically how the requested discovery is burdensome, overbroad, or oppressive by submitting detailed affidavits or other evidence establishing the undue burden.” Wagner v. Viacost.com, No. 06-81113-CIV, 2007 WL 1879914, at *1 (S.D. Fla. June 29, 2007).

Objections asserted that are not addressed in a response to a motion to compel are deemed to have been abandoned. See, e.g., Jackson v. Geometrica, Inc., No. 3:04-cv-640-J-20HTS, 2006 WL 213860, at *1 (M.D. Fla. Jan. 27, 2006). General objections to discovery requests as a whole are not proper. See, e.g., Fed. R. Civ. P. 33(b)(4) (the grounds for objecting to each interrogatory must be stated with specificity); Fed. R. Civ. P. 34(b)(2)(B) (the response to each request for production must state that inspection will be permitted and documents produced or state an objection to the request including the reasons for the objection).

III. ANALYSIS.

A. Relevance of Discovery Sought.

*2 As an initial matter, Plaintiff objects to the information sought in some of Defendant's interrogatories because Defendant “seeks to obtain information about what actually occurred between [Plaintiff] and Jane Roe on the night of the Incident,” which Plaintiff contends is not relevant to his claims in this case. Doc. No. 41, at 2. Defendant argues that the events surrounding the underlying incident are relevant and discoverable because Plaintiff placed those underlying facts at issue in his complaint and those facts relate to both the erroneous outcome and breach of contract claims. Doc. No. 40, at 4–5.

Erroneous outcome claims allege that “the plaintiff was innocent and wrongly found to have committed an offense.” Yusuf v. Vassar Coll., 35 F.3d 709, 715 (2d Cir. 1994). “To state a claim for erroneous outcome discrimination, a plaintiff must allege (1) ‘a procedurally or otherwise flawed proceeding’; (2) ‘that has led to an adverse and erroneous outcome’; and (3) ‘particular circumstances suggesting that gender bias was a motivating factor behind the erroneous finding.’ ” Doe v. Salisbury Univ., 123 F. Supp. 3d 748, 766 (D. Md. 2015) (quoting Yusuf, 35 F.3d at 715).

In Count I of the amended complaint, Plaintiff alleges that the proceeding administered by Defendant resulted in an erroneous outcome because Defendant presumed Plaintiff guilty from the beginning of the case; it acted with impermissible gender bias; and it discriminated against Plaintiff based on his gender by, among other things, failing to conduct a full and fair investigation and ignoring significant evidence. Doc. No. 14, at 32–34. Accordingly, because Plaintiff's erroneous outcome claim relates to whether Defendant properly found him responsible for the underlying incident and contests that Defendant considered all of the pertinent evidence related to that claim, it appears that discovery related to the facts concerning the underlying incident are discoverable.[1]

The facts of the underlying incident are also relevant to Plaintiff's breach of contract claim. Plaintiff argues that because his breach of contract claim only relates to Defendant's bias or procedural flaws in the investigation, which encompass only the evidence uncovered during Defendant's investigation and do not relate to the merits of Ms. Roe's allegations, the merits of the underlying incident are irrelevant. Doc. No. 41, at 5–6. Defendant, on the other hand, contends that Plaintiff's complaint puts both the events leading up to the incident and the incident itself at issue. Doc. No. 40, at 5–6.

*3 In Count III of the amended complaint, Plaintiff alleges that Defendant violated its Sexual Misconduct Policy by, among other things: (1) employing a biased investigator, who based his report on rumor, innuendo and hearsay “in spite of significant contrary evidence” and failed to give Plaintiff an opportunity to cross-examine or question Jane Roe; (2) considering Plaintiff's prior sexual history in violation of the policy; and (3) finding Plaintiff responsible without sufficient evidence because there was no physical evidence, and the circumstantial evidence contradicted Ms. Roe's allegations. Doc. No. 14, at 44–45. Because these allegations dispute the sufficiency of the evidence against Plaintiff, and question how Defendant utilized the evidence in its investigation, the facts regarding the underlying incident are relevant to Plaintiff's claims. Accordingly, Plaintiff's general relevancy objections are overruled.

B. General Objections.

Plaintiff also asserts the following general objections to Defendant's first set of interrogatories and first requests for production:

See Doc. No. 40, at 12.

General or blanket objections should be used only when they apply to every discovery request at issue. Here, these general objections do not apply to all of Defendant's discovery requests. For example, Plaintiff has not established that any information sought would be privileged or protected and, thus, the third general objection based on privileges and protections does not appear to apply to any of the discovery requests at issue. See Mullins v. Encore Senior Living II, LLC, No. 3:07-cv-325/WS/EMT, 2007 WL 4098851, at *1 n.1 (N.D. Fla. Nov. 16, 2007) (“[A] baldfaced assertion [of privilege or protection] is insufficient....” (quoting Peat, Marwick, Mitchell & Co. v. West, 748 F.2d 540, 542 (10th Cir. 1984))). Similarly, the sixth general objection pertains to expert materials, while none of the interrogatories or requests at issue in the instant motion to compel encompass expert-related materials. Additionally, not all of Defendant's discovery requests are overbroad or unduly burdensome, as stated in the second objection. Therefore, these general objections are overruled. The Court will consider these objections only to the extent such objection is asserted in response to a specific request for production or interrogatory and supported in the response to the motion to compel. See Desoto Health & Rehab, L.L.C. v. Philadelphia Indem. Ins. Co., No. 2:09-cv-599-FtM-99SPC, 2010 WL 2330286, at *1 (M.D. Fla. June 10, 2010).

C. Interrogatory No. 5.

*4 Defendant served the following interrogatory on Plaintiff:

Plaintiff responded:

Doc. No. 40, at 3.

As discussed above, Plaintiff's objection on relevancy grounds is overruled. Moreover, Plaintiff's complaint raises the issue of Plaintiff's and Ms. Roe's alcohol consumption prior to the incident. E.g., Doc. No. 14 ¶ 13. Accordingly, the information requested in Interrogatory No. 5 is relevant.

In addition, in response to Interrogatory No. 5, Plaintiff responded in part to the interrogatory while attempting to preserve his specific and general objections. Objections followed by a partial answer waive the objections unless the response explains with specificity what is being withheld. See Tardif v. People for the Ethical Treatment of Animals, No. 2:09-cv-537-FtM-29SPC, 2011 WL 1627165, at *2 (M.D. Fla. April 29, 2011) (noting that “courts have found that whenever an answer accompanies an objection, the objection is deemed waived ...”); Siddiq v. Saudi Arabian Airlines Corp., No. 6:11-cv-69-Orl-19GJK, 2011 WL 6936485, at *3 (M.D. Fla. Dec. 7, 2011). Because Plaintiff provided an answer responsive to Interrogatory No. 5 without specifically explaining what was withheld, his objections are overruled.

Accordingly, Defendant's motion to compel a full and complete response to Interrogatory No. 5 is GRANTED.

D. Interrogatory No. 6.

Defendant served the following interrogatory to Plaintiff:

*5 Plaintiff responded:

Doc. No. 40, at 6–7. As discussed above, Plaintiff's objection on relevancy grounds is overruled. Moreover, because Plaintiff provided an answer responsive to Interrogatory No. 6, but did not state with specificity what information was not being supplied, his objections are overruled. 40, at 7. Accordingly, Defendant's motion to compel a full and complete response to Interrogatory No. 6 is GRANTED.

E. Interrogatory No. 7.

Defendant served the following interrogatory to Plaintiff:

Plaintiff responded:

Doc. No. 40, at 7–8.

Defendant explains that in the complaint, Plaintiff identified text messages between himself and Ms. Roe and that the evidence during the investigation included information from his personal electronic devices. Thus, Defendant asserts that it is “entitled to discover, what electronic devices and how many, Plaintiff owned and utilized during the relevant time period.” Doc. No. 40, at 8.

*6 In response, Plaintiff maintains that this request is overly broad, seeks irrelevant information and is set forth for harassment purposes. He also asks that the Court review Interrogatory No. 7 in light of a separate request for production of such devices by Defendant (“Request No. 6”). Plaintiff represents that it will answer Interrogatory No. 7 if Defendant withdraws Request No. 6. Doc. No. 41, at 7–8. However, because Request No. 6 is not a subject of the instant motion to compel, I decline to analyze these discovery requests jointly. By itself, Interrogatory No. 7 is not overly broad or unduly burdensome because it only seeks a list of Plaintiff's electronic devices used over a two-year period, which period is encompassing of the underlying investigation and the events leading thereto. See Doc. No. 14, at 3–19. Accordingly, Plaintiff's objections to Interrogatory No. 7 are overruled, and Defendant's motion to compel a full and complete response is GRANTED.

F. Request for Production No. 3.

In Request No. 3, Defendant seeks:

Plaintiff responded:

Doc. No. 40, at 9.

In response to the motion to compel, Plaintiff claims that he has provided documentation responsive to Request No. 3 and has informed Defendant that he has “no other documents related to the investigation or adjudication of the claims of sexual misconduct.” Doc. No. 41, at 10. Because Plaintiff has provided responsive documents to this request, his objections based on vagueness, overbreadth or undue burden are overruled. See, e.g., Spitznagel v. R & D Italia, LLC, No. 2:09-CV-824-FTM-36SPC, 2011 WL 13143144, at *4 (M.D. Fla. Apr. 14, 2011) (“[B]ecause Plaintiff objected to this Request, but then responded by providing responsive documents, it has waived any objection to producing documents responsive to this Request and if any further documents are in Plaintiff's possession, they are due to be produced.”). Plaintiff also states that insofar as Defendant seeks to obtain documents containing “communications ‘with individuals regarding the Incident’ with Jane Roe,” the request is not relevant under Yusuf. Doc. No. 41, at 10. As discussed above, however, Plaintiff's objection on relevancy grounds as to the facts pertaining to the underlying incident is overruled. Therefore, Defendant's motion to compel documents responsive to Request No. 7 is GRANTED.

G. Request for Production No. 9.

Finally, Defendant seeks to compel Plaintiff to respond to Request No. 9, which seeks:

Plaintiff responded:

*7 Doc. No. 40, at 10–11.

Defendant argues that the information sought is discoverable because Plaintiff's complaint includes allegations of social stigma and its effects on his employment opportunities and mental anguish and depression, the information is relevant to Plaintiff's damages and state of mind. Id. at 11–12. Plaintiff responds that this request is overbroad because it contains no subject-matter limitations and is not limited to posts related to the investigation or adjudication of the claims of sexual misconduct. Doc. No. 41, at 10.

Plaintiff's objection is well taken. “Although discovery provisions are broadly and liberally construed, a request still must be tailored to appear ‘reasonably calculated to lead to the discovery of admissible evidence.’ ” See Palma v. Metro PCS Wireless, Inc., 18 F. Supp. 3d 1346, 1347 (M.D. Fla. 2014) (citing Fed. R. Civ. P. 26(b)(1)). Defendant's request is not limited to a particular subject matter, nor has Defendant explained how a broad all-encompassing sweep of Plaintiff's social media is proportional to the needs of the case. See, e.g., id. (finding request for all posts from social media accounts for four-year period, including private messages send from social media sites, to be overbroad and overly burdensome; defendant had also not established relevance); cf. Excel Fortress Ltd. v. Wilhelm, No. CV-17-04297-PHX-DWL, 2018 WL 6067255, at *5 (D. Ariz. Nov. 20, 2018) (“Although some of Defendants’ cell phone records may be properly subject to discovery, Plaintiffs’ insistence on demanding the production of personal cell phone records with no connection to the claims asserted in the complaint renders this request—like so many of the others—overbroad.”).

Accordingly, Defendant's motion to compel documents responsive to Request No. 9 is DENIED.

IV. CONCLUSION.

Based on the foregoing, Defendant's Motion to Compel Responses to Defendant's First Set of Interrogatories and First Request for Production (Doc. No. 40) is GRANTED in part and DENIED in part. It is ORDERED that, on or before March 12, 2019, Plaintiff shall provide to Defendant full and complete sworn responses to Interrogatories 5, 6 and 7. It is further ORDERED that on or before March 12, 2019, Plaintiff shall also produce for inspection and copying documents and tangible things responsive to Request No. 3.

DONE and ORDERED in Orlando, Florida on February 27, 2019.