*1 This case is before the Court on four discovery motions.[1] First, Plaintiff filed a Contested Motion to Strike the Hinshaw[2] and ZRFM[3] Defendants’ Privilege Logs and to Compel Production of Withheld Documents [ECF No. 93]. The Court granted that Motion in part [ECF No. 101] and ordered Defendants to produce a more fulsome privilege log, which they have done. The Motion was taken under advisement to the extent Plaintiff argued an “at issue” waiver of attorney-client privilege by Defendants. All parties have since briefed the “at issue” waiver question so it is ripe for decision. [ECF Nos. 106, 107, 132]. Plaintiff also objects to the sufficiency of Defendants’ joint amended privilege log.

Second, Plaintiff moved to Compel Production of Mobile Phone for Inspection and Data Collection Pursuant to Written Protocol [ECF No. 122]. Zukowski Defendants then moved to Strike Plaintiffs Discovery Objections and to Compel Plaintiff's Discovery Responses and Motion for Entry of a Protective Order. [ECF Nos. 127, 138, 142]. Finally, Plaintiff filed a Contested Motion to Strike Zukowski Defendants’ Discovery Objections and to Compel the Zukowski Defendants’ Discovery Responses. [ECF Nos. 134, 147, 156].

For the reasons discussed below, the motions are granted in part and denied in part.

I. Plaintiff's Motion to Strike Defendants’ Joint Amended Privilege Log

On September 10, 2019, Defendants filed a joint amended privilege log, asserting their intention under Federal Rule of Civil Procedure 26(b)(5) to withhold approximately 500 documents based on the attorney-client privilege and work product doctrines. Plaintiff argues that notwithstanding Defendants’ complete overhaul of their privilege log after the Court's earlier ruling [ECF No. 101], Defendants’ newly-submitted joint amended privilege log remains deficient for several reasons. Plaintiff claims, as a general matter, the amended log does not set forth sufficient information to determine why each communication is privileged. Plaintiff further argues the log does not identify which portions of certain communications may not be privileged, nor does it identify to which of Plaintiff's production requests or Defendants’ affirmative defenses or counterclaims the documents are responsive or relate. Finally, Plaintiff complains that some the descriptions from a prior privilege log conflict with those described in the joint amended privilege log and asserts that this “raise[s] serious questions.” Plaintiff's Reply in Support of his Contested Motion to Strike [ECF No. 132] at 3. The Court has reviewed Defendants’ joint amended privilege log and, for the reasons stated below, finds it is sufficiently detailed to pass muster under Rule 26(b). Plaintiff's Motion, therefore, is denied as it pertains to the purported deficiency of Defendants’ privilege log.

*2 “Under Federal Rule of Civil Procedure 26(b)(5), a party withholding a document on the basis of a privilege must ‘expressly make the claim.’ ” In re: Fluidmaster, Inc., 2016 WL 6599947, at *5 (N.D. Ill. 2016) (quoting FED.R.CIV.P. 26(b)(5)(A)(i)). The proponent of the privilege – in this case Defendants - bears the burden of establishing the document is protected by the attorney-client or work product doctrine as to each document for which protection against production is claimed. RTC Indus., Inc. v. Fasteners for Retail, Inc., 2019 WL 5003681, at *2 (N.D. Ill. 2019); see also, United States v. BDO Seidman, 337 F.3d 802, 811 (7th Cir. 2003) (“The mere assertion of a privilege is not enough; instead, a party that seeks to invoke the attorney-client privilege has the burden of establishing all of its essential elements”). This is generally done through a privilege log that “describe[s] the nature of the documents, communications, or things not produced or disclosed—and do[es] so in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim.” FED.R.CIV.P. 26(b)(5)(A)(ii).

As the Court's case procedures relating to privilege logs describe, “[a]ny privilege log must be detailed enough to enable other parties to assess the applicability of the privilege asserted and should include: (1) the name and capacity of each individual from whom or to whom a document and any attachments were sent (including which persons are lawyers); (2) the date of the document and any attachments; (3) the type of document; (4) the Bates numbers of the documents, (5) the nature of the privilege asserted; and (6) a description of the subject matter of the information contained in the document in sufficient detail to determine if legal advice was sought or received or if the document constitutes attorney work product.” Magistrate Judge Jeffrey T. Gilbert, Case Procedures, Privilege Logs, https://www.ilnd.uscourts.gov/judge-info.aspx?QZFvvligiJ0= (last visited November 19, 2019) (citing Allendale Mut. Ins. Co. Bull Data Systems, Inc., 145 F.R.D. 84, 88 (N.D. Ill. 1992)).

Defendants’ privilege log is sufficiently detailed to enable both Plaintiff and the Court to assess the applicability of the two privileges asserted. Allendale, 145 F.R.D. at 88. In the Court's review, the log contains precisely the information contemplated in the above case procedures: the names of each individual from or to whom the document was sent or copied, as well as whether or not they are attorneys; the date each document was received, if applicable; the type of document and its corresponding Bates number; the nature of the privilege asserted, whether attorney-client privilege, work product privilege, or both; and a specific description of the subject of each communication and whether legal advice was sought or received, if applicable.

While Defendants did not identify the production request, affirmative defense, or counterclaim to which each privileged document is responsive or relates, that is not what Rule 26(b)(5) requires. Rather, Defendants must identify the reason they are withholding the document from production, which they did in this case by categorizing each communication contained in the privilege log and providing a color-coded ledger of the same. See, e.g., RBS Citizens, N.A. v. Husain, 291 F.R.D. 209, 218 (N.D. Ill. 2013) (the party asserting privilege over a document must identify, among other things, the purpose for that document's production) (citing Muro Target Corp., 2006 WL 3422181, at *2 (N.D. Ill. 2006)). For example, through their ledger, Defendants color-coded all legal research and related legal advice conducted by the Hinshaw Defendants on behalf of the ZRFM Defendants in the Kimberly Popovich (“Popovich”) malpractice case in orange. This allows both Plaintiff and the Court to readily identify the reason each orange-coded document is being withheld from production in this case. While the Court notes that color coding is helpful in this instance, it is by no means required under the Federal Rules. Defendants therefore have satisfied their burden of specificity under Rule 26(b)(5) in this respect.

*3 No more availing is Plaintiffs argument that Defendants’ log fails to identify which portions of certain communications may not be privileged. Based on the types of documents withheld and the people identified in each communication, it would not be proportionate to the needs of this case to order Defendants’ to dissect the withheld documents on a line-by-line basis. Almost every document withheld by Defendants based on attorney-client privilege involves a direct communication from a lawyer to a lawyer, concerning legal advice related to ongoing litigation. In the Court's view, therefore, the documents are “so pervasively filled” with privileged material that the entire document very likely is privileged. See, e.g., IBJ Whitehall Bank & Tr. Co. v. Cory & Assocs., Inc., 1999 WL 617842, at *9 (N.D. Ill. 1999). Ordering Defendants to surgically redact every document in this circumstance would almost certainly be a time consuming, expensive, and an ultimately unhelpful and fruitless endeavor.

Finally, the “serious questions” Plaintiff raises with respect to differences between Defendants’ original and amended privilege logs are without merit. As an initial matter, it is unclear to the Court what legal remedy Plaintiff seeks for the “conflicting log entries” he has identified, other than to simply bring his concerns to the Court's attention. Nevertheless, whether Defendants’ original privilege log conflicts with their amended log is irrelevant. All parties, including the Court, intended that Defendants’ joint amended privilege log would supersede the original privilege log and stand on its own as Defendants’ express assertion of privilege under Federal Rule of Civil Procedure 26(b)(5). Indeed, allowing Plaintiff to continue to raise concerns or conflicts with Defendants’ original privilege log here would entirely undercut and confuse the practice of allowing a party to amend a deficient privilege log in the first place. See, e.g., Muro v. Target Corp., 250 F.R.D. 350, 359-60 (N.D. Ill. 2007) (holding that where the defendant produced a second privilege log pursuant to court order, “any issues relating to the adequacy of the first log are irrelevant”).

For the reasons discussed above, Plaintiff's objections to the sufficiency of Defendants’ joint amended privilege log are overruled.

II. The “At Issue” Waiver Doctrine

Plaintiff next contends that Defendants have put their confidential communications “at issue” in this litigation and have therefore waived the attorney-client privilege for every document contained in their privilege log. Plaintiff specifically asserts that Hinshaw Defendants have raised certain affirmative defenses in this case that “implicate their representation of ZRFM Defendants in the Popovich legal malpractice suit.” Plaintiff's Reply in Support of his Contested Motion to Strike [ECF No. 132] at 4. According to Plaintiff, this lifts the veil of attorney-client privilege as to all confidential communications between Hinshaw Defendants and ZRFM Defendants related to the Popovich litigation.

Specifically, Plaintiff cites two of Hinshaw Defendants’ affirmative defenses that he says result in the waiver of Defendants’ claim of attorney-client privilege: (1) an affirmative defense entitled “Litigation Privilege” in which Hinshaw Defendants assert that their “alleged conduct occurred during the course of a judicial proceeding and the discovery of Plaintiff's assistance to Ms. Popovich in drafting the malpractice complaint and providing additional advice and assistance was directly related to Hinshaw's defense of the malpractice claim,” and (2) a “Good Faith Reliance on Court Order” defense in which Hinshaw Defendants assert that they relied on a court order issued in the Popovich malpractice litigation to justify their conduct related to Plaintiff's ZRFM-issued phone. The Hinshaw Defendants’ Answer and Affirmative Defenses to Amended Complaint [ECF No. 131] at 39-40, 42-43. Notwithstanding the fact that Defendants have not withheld all the documents on their privilege log on the basis of attorney-client privilege – some have been withheld as work product or pursuant to court rules - Plaintiff demands that Defendants’ joint amended privilege log be stricken and every document referenced therein be produced as a result of Defendants’ purported “at issue” waiver.

*4 The attorney-client privilege is “one of the oldest recognized privileges for confidential communications,” United States v. BDO Seidman, 337 F.3d 802, 810 (7th Cir. 2003), and exists primarily to “ ‘encourage full and frank communication between attorneys and their clients.’ ” United States Zolin, 491 U.S. 554, 562 (1989) (quoting Upjohn Co. v. United States, 449 U.S. 383, 389 (1981)). However, the attorney-client privilege can be waived, either explicitly or by implication. Lorenz v. Valley Forge Ins. Co., 815 F.2d 1095, 1098 (7th Cir. 1987); see also, United States v. Nobles, 422 U.S. 225, 239 (1975); United States v. Brock, 724 F.3d 817, 821 (7th Cir. 2013). Express waiver occurs where “information that would otherwise be privileged is not kept confidential.” Patrick v. City of Chicago, 154 F. Supp. 3d 705, 711 (N.D. Ill. 2015). Implied waiver can occur when a client asserts claims or defenses that put his or her attorney's advice “at issue” in the litigation. Paters United States, 159 F.3d 1043, 1047 (7th Cir. 1998).

As this Court previously emphasized in United States ex rel. Derrick Roche Diagnostics Corp., 2019 WL 1789883 (N.D. Ill. 2019), the “at issue” waiver doctrine is limited and “should not be used to eviscerate the attorney-client privilege.” Silverman Motorola, Inc., 2010 WL 2697599 at *4 (N.D. Ill. 2010) (citing LG Electronics v. Whirlpool Corp., 2009 WL 3294802 (N.D. Ill. 2009)). Fatal to Plaintiff's argument here is that merely asserting a claim or defense to which attorney-client communications are relevant, without more, does not constitute a waiver of attorney-client privilege. The privileged party must affirmatively put at issue the specific communication to which the privilege attaches before the privilege will be deemed waived. United States v. Capital Tax Corp., 2011 WL 1399258 (N.D. Ill. 2011); Beneficial Franchise Co., Inc. v. Bank One, N.A., 205 F.R.D. 212, 216 (N.D. Ill. 2001); see also, Rhone-Poulenc v. Rorer Inc. v. Home Indemnity Co., 32 F.3d 851, 863 (3d Cir. 1994). Defendants have not done so in this case. As Plaintiff himself stated, Hinshaw Defendants have done no more than “implicate their representation of ZRFM Defendants in the Popovich legal malpractice suit” and generally describe attorney involvement in ARDC matters also related to the Popovich litigation. They have not, either according to Plaintiff or in the Court's review, attempted to prove any of their broadly pled affirmative defenses by disclosing or describing specific attorney-client communications. It is also unclear that they must inevitably do so by asserting those defenses. There has therefore been no waiver of attorney-client privilege. Silverman, 2010 WL 2697599 at *4 (“at issue” waiver applies only where the client asserts a claim or defense and attempts to prove that claim or defense by disclosing or describing attorney-client communication). To hold otherwise would not only expand the “at issue” waiver doctrine far beyond its intended narrow scope but also run directly contrary to the spirit of fairness that animates every question of waiver of attorney-client privilege. Derrick, 2019 WL 1789883, at *4. Especially at this early stage of litigation, the Court will not endorse forcing Defendants to make the “draconian choice” between abandoning their affirmative defenses or sacrificing any claim of attorney-client privilege to pursue them. Beneficial Franchise Co., 205 F.R.D. at 216.

Plaintiff's motion to compel production of all documents withheld by Defendants as listed in their joint amended privilege log based on the “at issue” waiver of attorney-client privilege therefore is denied.

III. Zukowski Defendants’ Motion Strike Plaintiff's Discovery Objections and to Compel Plaintiff's Discovery Responses

*5 Aside from issues involving Defendants’ joint amended privilege log, both Plaintiff and Zukowski Defendants contend each other's respective objections to written discovery requests are improper. The Court first turns to Zukowski Defendants’ Motion Strike Plaintiff's Discovery Objections and to Compel Plaintiff's Discovery Responses and Motion for Entry of a Protective Order. [ECF Nos. 127, 138, 142].

Zukowski Defendants seek to strike Plaintiff's Discovery Objections on six separate points: (1) Plaintiff's incorporation by reference of “general objections” into every discovery response; (2) Plaintiff's objections to certain interrogatories that he claims are “premature” because Zukowski Defendants’ had not yet filed their answer or affirmative defenses; (3) Plaintiff's objections that discovery related to the Popovich litigation and Plaintiff's employment with ZRFM, as well as a specific request for Plaintiff's tax returns, is not relevant; (4) Plaintiff's objections, without more explanation, that certain requests are overly broad or unduly burdensome; (5) Plaintiff's citations to entire discovery productions without providing any more narrowing information to ascertain which documents are responsive to the request; and (6) Zukowski Defendants’ contention that Plaintiff is withholding responsive documents. Zukowski Defendants also ask the Court to enter a protective order preventing Plaintiff from conducting a second inspection of Plaintiff's ZRFM-issued phone.

Taking each issue in turn, repetitive, boilerplate objections serve no productive purpose in the discovery process. BankDirect Capital Fin., LLC v. Capital Premium Fin., Inc., 2017 WL 5890923, at *2 (N.D. Ill. 2017) (collecting cases); Fudali v. Napolitano, 283 F.R.D. 400, 403 (N.D. III. 2012); Burkybile v. Mitsubishi Motors Corp., 2006 WL 2325506, at *6 (N.D. Ill. 2006). Objections must be stated “with specificity.” FED.R.CIV.P. 33(b)(4). General objections, therefore, are “tantamount to not making any objection at all.” E.E.O.C. v. Safeway Store, Inc., 2002 WL 31947153, *2–3 (N.D. Cal. 2002); BankDirect Capital Fin., LLC, 2017 WL 5890923, at *2. And yet, in this Court's view, the use of boilerplate objections “continues unabated, with the consequent burdens on the parties and the court, which is called upon to resolve them.” Fudali v. Napolitano, 283 F.R.D. 400, 403 (N.D. Ill. 2012). Instead, the burden is on the objecting party – in this case, Plaintiff – to show why the request is improper. “That burden cannot be met by a reflexive invocation of the same baseless, often abused litany that the requested discovery is vague, ambiguous, overly broad, unduly burdensome or that it is neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.” Burkybile Mitsubishi Motors Corp., 2006 WL 2325506, at *6 (N.D. Ill. 2006) (internal quotations omitted). For this reason, “[m]aking general objections is a dangerous practice, as the party who offers such general objections runs the risk of having them summarily denied.” Avante Int'l Tech., Inc. v. Hart Intercivic, Inc., 2008 WL 2074093, at *2 (S.D. Ill. 2008).

Plaintiff argues that his General Objections are not “blanket objections” but merely “definitional.” This is a distinction in name only: Plaintiff's General Objections, which he incorporates into each response to Defendants’ discovery requests, are precisely the type of nonspecific, boilerplate objections courts repeatedly caution against. Novelty, Inc. v. Mountain View Mktg., 265 F.R.D. 370, 375 (S.D. Ind. 2009) (“general objections made without elaboration, whether placed in a separate section or repeated by rote in response to each requested category, are not objections at all—and will not be considered”). For example, General Objection B objects to every discovery request to the extent a response would result in the “inadvertent provision of information or production of documents protected by attorney-client privilege, work product doctrine or other applicable privilege.” This is wholly inadequate to preserve a claim of privilege and ignores the clear process provided by Rule 26(b)(5) for asserting privilege. It therefore has no merit as a discovery objection. Nor do Plaintiff's other “general objections” have any more substance to them.

*6 Therefore, to the extent Plaintiff has agreed to withdraw General Objections C, D, and E in his Motion, the Court considers these objections withdrawn. Plaintiff's Response to Zukowski Defendants’ Contested Motion to Strike [ECF No. 138] at 2. In all other respects, Defendants’ Motion to Strike Plaintiff's boilerplate objections is granted, specifically as to General Objections B, F, and G. To the extent Plaintiff withheld responsive documents based solely on these General Objections, he is ordered to produce them or serve a more fulsome response in compliance with the Rules. If Plaintiff did not withhold any documents based on these General Objections, he should so inform Defendants in writing. If Plaintiff amends his discovery responses in light of this ruling, the parties shall endeavor to meet and confer under Local Rule 37.2 in any effort to resolve any remaining disputes before seeking the assistance of the Court.

Zukowski Defendants next seek to strike Plaintiff's objections to Interrogatory Nos. 2, 3, 4, 5, and 12, as well as Document Request Nos. 1, 3, 4, 5, 6, 7, 8, 11, 12, 13, 14, 15, 17, 18, 19, 21, 22, and 23 as “premature.” At the time of Plaintiff asserted these objections, Zukowski Defendants had not yet filed an answer or affirmative defenses. Plaintiff claimed he was excused from his obligation to respond to the discovery requests noted above until a responsive pleading was filed. As Defendants point out, without disagreement from Plaintiff, Plaintiff agreed during the meet and confer process to withdraw all the above-described “premature” objections. And while Plaintiff omits reference to this agreement in his response, the fact that Zukowski Defendants filed their answer and affirmative defenses two months ago further supports the conclusion that this dispute is moot. Assuming without decision that those objections ever had any merit at all, Plaintiff's objections to the above-noted interrogatories and document requests as premature therefore are overruled.

Plaintiff further objected to Interrogatory Nos. 3, 5, and 12 and Document Request Nos. 5, 6, 7, 8, 12, 13, 14, 15, and 17 based on relevance. Zukowski Defendants assert that Plaintiff's employment with ZRFM, his communications with Popovich related to the malpractice action, and his alleged involvement in the disclosure of ARDC letters – the general subject matters of Plaintiff's relevance objections – are directly relevant to the discovery process in that the information sought is likely to illuminate whether “Zukowski Defendants’ actions are highly offensive or objectionable to a reasonable person, whether Plaintiff had an expectation of privacy in the information alleged[ly] accessed, and whether extracted information that was stored on the phone is in fact private.” Zukowski Defendants’ Motion to Strike Plaintiff's Discovery Objections [ECF No. 127] at 7. Plaintiff responds, in a single sentence, that the objected-to interrogatories and document requests are irrelevant because “Zukowski Defendants made certain assertions related to Plaintiff's employment that are not issues raised in Plaintiff's First Amended Complaint (Doc #68), and then sought through discovery to make requests even though no claims had ben asserted with respect to Plaintiff's employment,” Plaintiff's Response to Zukowski Defendants’ Contested Motion to Strike [ECF No. 138] at 2-3.

Federal Rule of Civil Procedure 26(b)(1), which governs the general scope of discovery, allows parties to obtain discovery regarding any matter, not privileged, which is relevant to the claim or defense of any party. Because the purpose of discovery is to help “define and clarify the issues,” relevance is to be construed broadly. Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978); see also, Tice American Airlines, Inc., 192 F.R.D. 270, 272 (N.D. Ill. 2000) (“the scope of discovery should be broad in order to aid in the search for truth.”). “If relevance is in doubt, courts should err on the side of permissive discovery.” Wiginton CB Richard Ellis, Inc., 229 F.R.D. 568, 577 (N.D. Ill. 2004).

*7 Relevance is not the end of the inquiry under Rule 26. The 2015 amendments to Rule 26(b)(1) expressly inserted the concept of “proportionality” into the Rule by adding language that discovery must be “proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties relative access to relevant information, the parties resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” FED. R. CIV. P. 26(b)(1).

Zukowski Defendants’ Motion is based, in part, on an outdated understanding of Rule 26(b)(1). Zukowski Defendants incorrectly assert that “[r]elevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.” Zukowski Defendants’ Motion to Strike Plaintiff's Discovery Objections [ECF No. 127] at 6-7. Yet this language was expressly removed from Rule 26(b)(1) when it was amended in 2015. At that time, the Advisory Committee deleted “the former provision for discovery of relevant but inadmissible information that appears ‘reasonably calculated to lead to the discovery of admissible evidence’ ” because it had “been used by some, incorrectly, to define the scope of discovery. As the Committee Note to the 2000 amendments observed, use of the ‘reasonably calculated’ phrase to define the scope of discovery ‘might swallow any other limitation on the scope of discovery.’ The 2000 amendments sought to prevent such misuse by adding the word ‘Relevant’ at the beginning of the sentence, making clear that “ ‘relevant’ means within the scope of discovery as defined in this subdivision ...” The ‘reasonably calculated’ phrase has continued to create problems, however, and is removed by these amendments. It is replaced by the direct statement that ‘Information within this scope of discovery need not be admissible in evidence to be discoverable.’ ” Advisory Committee Notes, FED. R. CIV. P. 26(b)(1); see also, In re Broiler Chicken Antitrust Litig., 2018 WL 3586183, at *3 (N.D. Ill. 2018). Zukowski Defendants’ reliance on the above-quoted language from an outdated version of Rule 26(b)(1) – and cases that interpret it – therefore is misplaced.

The burden rests upon the objecting party to show why a particular discovery request is improper under Rule 26(b)(1). Rubin v. Islamic Republic of Iran, 349 F.Supp.2d 1108, 1111 (N.D. Ill. 2004). Plaintiff has not met that burden here, where he merely concludes, without support, that because he did not specifically assert a claim “about his employment,” information about his employment at ZRFM cannot be relevant, including to any other claim or defense. Not only is this illogical on its face, but Defendants have in fact made a specific showing that Plaintiffs employment at ZRFM, his communications with Popovich in the malpractice litigation, and Plaintiff's involvement in the disclosures to the ARDC are directly relevant to claims and defenses in this case within the meaning of Rule 26(b)(1). Namely, discovery related to these subjects is relevant to the legal elements of several claims Plaintiff has asserted against Defendants, including that Defendants’ actions were “highly offensive or objectionable to a reasonable person, whether Plaintiff had a reasonable expectation of privacy in the information allegedly accessed, and whether the information extracted from ZRFM's cell phone was in fact, private.” Zukowski Defendants’ Reply in Support of Their Motion to Strike [ECF No. 142] at 5.

*8 Defendants’ requests not only are relevant, but they are proportional to the needs of the case within the meaning of Rule 26(b)(1). Answering Defendants’ interrogatories and responding to their document requests on these subject matters does not impose a great burden on the Plaintiff. By Plaintiff's own admission, he already identified the responsive documents as part of his Mandatory Initial Discovery Pilot (“MIDP”) production. Plaintiff's Response [ECF No. 138] at 3. Furthermore, this discovery is of central importance to resolving the issue at the heart of this litigation. For these reasons, Plaintiff's objections to the above-noted interrogatories and document requests are overruled and Zukowski Defendants’ Motion is granted in this respect.

Plaintiff further objects to production of his tax returns from 2017 to the present, stating he has not put the level and sources of his income at issue. Zukowski Defendants counter that Plaintiff's tax returns are directly relevant to the damages Plaintiff seeks to recover in this case for his “harmed reputation” as an attorney, as well as to Zukowski Defendants’ affirmative defenses of failure to mitigate and no actual damages resulting from Plaintiff's intrusion upon seclusion claim.

It is well-settled that “[t]ax returns in the hands of a taxpayer are not privileged” from discovery. Poulos Naas Foods, Inc., 959 F.2d 69, 74 (7th Cir. 1992). And although “[s]ome courts have suggested that there is a heightened showing that must be made before tax returns are discoverable,” such as a “compelling need for the information,” the Seventh Circuit has declined to adopt such a position. Jackson v. N'Genuity Enters. Co., 2010 WL 4928912, at *2 (N.D. Ill. 2010) (citing Poulos, 959 F.2d at 75). Tax returns, therefore, are subject to the familiar relevance and proportionality analysis under Rule 26(b)(1).

Here, Plaintiff's tax returns for 2017, 2018, and 2019 are relevant to Plaintiff's claims and Defendants’ defenses. Specifically, the returns are relevant to the ongoing damages Plaintiff has claimed for “harmed reputation” and Defendants’ defense of failure to mitigate. Johnson v. Soo Line R.R. Co., 2019 WL 4037963 (N.D. Ill. 2019); Fields General Motors Corp., 1996 WL 14040, at *3-4 (N.D. Ill. 1996) (granting motion to compel production of the plaintiffs’ tax returns where the plaintiffs’ claims for lost profits placed in issue their financial injury and whether they mitigated that injury); Shay v. Lifting Gear Hire Corp., 2012 WL 6680313, at *2 (N.D. Ill. 2012) (ordering plaintiff to produce his “personal W-2 and tax return statements” in age discrimination suit on the ground that this information “bears on the issue of mitigation and, therefore, must be produced.”). The request for the tax returns also is proportional to the needs of the case considering the minimal burden or expense that an order compelling production of the most recent three years of tax returns would impose on this individual Plaintiff. When compared to the likely benefit of production and considering that Defendants’ have no access to this relevant information absent Plaintiff's production, the Court finds the discovery of Plaintiff's tax returns is proportionate here and orders they be produced.

As for Plaintiff's assertions that Document Request Nos. 6, 7, 8, 12, 13, 14, and 15 are overly broad, the Court finds these objections without merit as framed. A party claiming that a request is unduly burdensome “must adequately demonstrate the nature and extent of the claimed burden by making a specific showing as to how disclosure of the requested documents and information would be particularly burdensome.” Rawat Navistar Intern. Corp., 2011 WL 3876957, at *8 (N.D. Ill. 2011); see also, FED.R.CIV.P. 34(b); Gile United Airlines, Inc., 95 F.3d 492, 495 (7th Cir. 1996). Plaintiff has failed to do so here, a fact he perhaps recognizes by declining to respond to Zukowski Defendants’ argument on this point. Despite raising a burden claim, Plaintiff has not addressed any issues relevant to that claim, such as the number of documents that would have to be reviewed, what costs would be incurred, or how long it would take to respond to Zukowski Defendants’ requests. See, e.g., Heraeus Kulzer, GmbH v. Biomet, Inc., 633 F.3d 591, 598 (7th Cir. 2011) (citing FED.R.CIV.P. 26(b)(2)(C)). Plaintiff's objections to Document Request Nos. 6, 7, 8, 12, 13, 14, and 15 therefore are overruled.

*9 Zukowski Defendants also ask the Court to compel Plaintiff to respond to Interrogatory Nos. 3, 9, 10, 12, 13, 14, and 18, as well as Document Requests 1, 4, 11, 12, 13, 15, 21, 22, and 23 with more particularity. In response to the above requests, Plaintiff directed Zukowski Defendants either to his or Defendants’ entire document production to date. A party responding to a document request under Rule 34 has a choice of producing the documents “as they are kept in the usual course of business” or of “organiz[ing] and label[ing] them to correspond with the categories in the request.” FED.R.CIV.P. 34(b)(2)(E)(i). While a responding party cannot hide responsive documents in a haystack, there is no duty incumbent on the party to organize and label the documents if it has produced them as they are kept in the usual course of business. Based on the Court's review, Plaintiff has not produced the documents in the ordinary course of business and has indeed failed to otherwise organize or index them in his response. Plaintiff therefore is ordered to respond to the above interrogatories and document requests in compliance with Rule 34(b). To the extent Plaintiff maintains the entire document production is relevant to each respective interrogatory or discovery request, then Plaintiff shall provide an index that specifies to which category each document produced is responsive.

Finally, Zukowski Defendants allege Plaintiff is withholding responsive documents. Specifically, Zukowski Defendants assert that Plaintiff is aware that numerous relevant emails between himself and Popovich exist and that he impermissibly failed to disclose them in his MIDP production. Defendants base their motion on more than mere suspicion, as Popovich provided Defendants with the emails exchanged with Plaintiff that are the subject of this motion as part of discovery in the malpractice action. Defendants, in turn, produced those emails to Plaintiff as part of their MIDP production in this case.

The Court's Standing Order Regarding MIDP requires, in relevant part, that Plaintiff “[l]ist the documents, electronically stored information (“ESI”), tangible things, land, or other property known by you to exist, whether or not in your possession, custody or control, that you believe may be relevant to any party's claims or defenses.” Magistrate Judge Jeffrey T. Gilbert, Mandatory Initial Discovery Pilot Project, Standing Order, https://www.ilnd.uscourts.gov/_assets/_documents/_forms/Judges/Gilbert/Standing% 20Order% 20Regarding% 20Mandatory% 20Initial% 20Discovery% 20Pilot% 20Project.pdf (last visited December 2, 2019) (emphasis added). Under the plain language of the MIDP, if Plaintiff is aware that he sent emails to Popovich that are relevant to his claims or Defendants’ defenses and he did not produce those emails, he is required to list those emails as part of his MIDP disclosure, even if they are no longer in his possession, custody or control. In other words, if he is no longer in possession of the emails, Plaintiff must so state. However, the MIDP does not require Plaintiff to inform Defendants of the reason(s) why such documents no longer exist, including whether he deleted or destroyed them. It is sufficient for purposes of the MIDP that Plaintiff comply with the plain language quoted above. The Court hereby orders Plaintiff do so to the extent his responses to date have been noncompliant regarding relevant emails he exchanged with Popovich.

IV. Zukowski Defendants’ Motion for Entry of a Protective Order and Plaintiff's Contested Motion to Compel Production of Mobile Phone for Inspection and Data Collection Pursuant to Written Protocol

Zukowski Defendants further ask the Court to enter a protective order preventing Plaintiff from conducting a second inspection of Plaintiff's ZRFM-issued phone. Plaintiff, unsurprisingly, seeks the opposite relief: a court order compelling Defendants to produce the mobile phone for inspection and data collection pursuant to a new written protocol. Plaintiff's Contested Motion to Compel Production of Mobile Phone [ECF No. 122]. Defendants argue that the information Plaintiff seeks to obtain through an inspection and data collection seeks is not relevant, and relatedly, that an inspection will not produce or uncover any probative evidence. Plaintiff strongly contends that a second phone inspection is necessary not only because his first inspection was unsuccessful, but also because a thorough data collection of the phone is as relevant now as it was a few months ago. Plaintiff asks that the inspection be compelled over Defendants’ objections.

*10 The Court has reviewed Plaintiffs proffer concerning the relevance of a second mobile phone inspection, including the affidavit of Nathan Binder, and finds that Plaintiff has not met his burden of establishing relevance and proportionality. Plaintiff asserts, both in his own motions and through the Binder Affidavit, no more than vague, conclusory statements that a second inspection “may lead to additional discoverable evidence.” Plaintiff's Response to Zukowski Defendants’ Contested Motion [ECF No. 138] at 5. Plaintiff further claims that he cannot “reveal[ ] too much,” but that both the Court and Defendants should find it “somewhat obvious” that a second inspection “may also reveal material contradictions with Defendants [sic] representations made in their responsive pleadings and discovery responses, as well as information supporting Plaintiff's claims against the defendants as alleged in his amended complaint.” Plaintiff's Response to Zukowski Defendants’ Contested Motion [ECF No. 138] at 5.

The Court cannot read Plaintiffs mind, and neither can Defendants. Nor has Plaintiff's hope that the relevance would be “somewhat obvious” to the Court borne fruit. Plaintiff's Response to Zukowski Defendants’ Contested Motion [ECF No. 138] at 5. Plaintiff's vague arguments provide no information upon which the Court can determine specifically to which claims or defenses any information obtained in the proposed inspection would be relevant. Nor does the Binder affidavit illuminate what information Plaintiff seeks to obtain from the mobile phone that is not already in his possession as a result of the D4 inspection. Rather, the Binder affidavit tracks Plaintiff's own conclusory statements and is of no help to the Court in determining the merits of this issue. Based on the current record, therefore, the Court finds Plaintiff has not established that a second inspection of the mobile phone is relevant and proportionate to the needs of this case under Rule 26. In the exercise of the Court's broad authority to enter a protective order to limit discovery “for good cause shown ... to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense,” FED. R. CIV. P. 26(c)(1), Defendants’ Motion for a Protective Order is granted. Plaintiff's Motion to Compel is denied.

V. Plaintiff's Contested Motion to Strike Zukowski Defendants’ Discovery Objections and to Compel Zukowski Defendants’ Discovery Responses

The Court now turns to Plaintiff's Contested Motion to Strike Zukowski Defendants’ Discovery Objections and to Compel the Zukowski Defendants’ Discovery Responses. [ECF Nos. 134, 147, 156]. In his Motion, Plaintiff asserts that Zukowski Defendants’ discovery objections are improper in three respects: (1) the repetition of boilerplate, blanket objections in Zukowski Defendants’ responses to Plaintiff's interrogatories and document requests; (2) Zukowski Defendants’ production of, and citation to, large quantities of documents, including a specific lack of detail related to intra-office ZRFM communications; and (3) Plaintiff's request for updated information regarding Zukowski Defendants’ insurance policy.

Plaintiff has moved to strike certain “general objections” from Zukowski Defendants’ responses to Document Request Nos. 2, 3, 4, 5, 6, 7, 8, 14, 16, 17, 19, 21, 22, 23, 25, 29, 31, 33, 37, 41, 45, and 47, as well as from ZRFM Interrogatory Nos. 5, 6, 8, and 9, Davis’ Interrogatory Nos. 2, 4, and 6, Flood's Interrogatory Nos. 2, 4, and 6, and McArdle's Interrogatory Nos. 2, 4, and 6. Specifically, Plaintiff takes issue with Zukowski Defendants’ repetition of the following phrases: “this request is not proportional to the needs of this case considering the marginal importance to the claims and defenses in this litigation” and “this request is overly broad, unduly burdensome, as it places no limitation in time and scope.” Plaintiff's Contested Motion to Strike [ECF No. 134] at 3-4. As discussed in detail above, repetitive, boilerplate objections are not welcome during the discovery process and will not be considered. BankDirect Capital Fin., LLC, 2017 WL 5890923, at *2. Objections not stated “with specificity,” FED.R.CIV.P. 33(b)(4), are “tantamount to not making any objection at all.” Safeway Store, Inc., 2002 WL 31947153, *2–3.

*11 The Court has reviewed the general phrases Plaintiff objects to in the document requests noted above and finds they are devoid of specificity and therefore improper as framed. For example, although Defendants claim each request they objected to is not proportionate to the needs of this case, Defendants do not specify how, let alone articulate if any of the proportionality factors set forth in Rule 26(b)(1) apply. And while a document request unlimited in time and scope may ultimately be overbroad, Defendants’ objections are simply too general for the Court to make this determination as it pertains to each specific request at issue. Therefore, Plaintiff's Motion to Strike Defendants’ boilerplate objections is granted. To the extent Defendants withheld responsive documents based solely on these general objections, they are ordered to produce them or serve a more fulsome response in compliance with the Rules. If Defendants did not withhold any documents based on these General Objections, they should so inform Plaintiff in writing. If Defendants amend their objections, the parties shall endeavor to meet and confer consistent with Local Rule 37.2 in any effort to resolve any remaining disputes before seeking the assistance of the Court.

Plaintiff further asserts that Zukowski Defendants improperly produced and cited large quantities of documents in response to Plaintiff's document requests.[4] Since the filing of Plaintiff's Motion to Strike, Zukowski Defendants have supplemented their production with an “Index” to aid in Plaintiff's review. [ECF No. 147-2]. Although Plaintiff maintains that this index is “unhelpful” and “of no consequence,” the Court has reviewed Defendants’ Index and Plaintiff's document requests and finds that the index satisfies Defendants’ burden under Rule 34 to “organize and label” the responsive documents “to correspond with the categories in [Plaintiff's] requests.” FED. R. CIV. P. 34(b)(2)(E)(i). In the Court's view, Plaintiff's broad document requests, in most cases, necessitated an equally broad document production and categorization on Defendants’ part. Furthermore, to the extent Plaintiff's motion seeks additional clarity regarding Zukowski Defendants’ production of internal ZRFM correspondence, Defendants have, in their response to Plaintiff's motion, indicated that additional responsive documents are forthcoming. If they have not already done so, Defendants promptly shall supplement their document production as it pertains to the intra-office ZRFM communications at issue here.

Plaintiff's request for rolling updates regarding Zukowski Defendants’ insurance policy limits also is without merit, as it is unsupported by the plain text of Rule 26(a)(1)(A)(iv). Defendants provided Plaintiff with a copy of an American Family Mutual Insurance Company policy as part of their MIDP production, as well as in response to Plaintiff's Document Request No. 13. This production satisfied Plaintiff's right to inspect and copy, under Rule 34, “any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment.” FED.R.CIV.P. 26(a)(1)(A)(iv). Especially given Plaintiff's failure to cite any relevant case law in support of his request, the Court finds Plaintiff is not entitled under the discovery rules to “periodically know the policy limits available.” Plaintiff's Contested Motion to Strike [ECF No. 134] at 5. No more is required of Zukowski Defendants as it pertains to Plaintiff's Document Request No. 13.

As a final matter, the parties repeatedly address the issue of Zukowski Defendants’ failure to timely serve their discovery responses some six months ago. As a consequence of Defendants’ delay, Plaintiff repeatedly demands that all written discovery responses served by Zukowski Defendants after the court-imposed deadline be stricken and “full and complete answers to the Rule 33 and Rule 34 written discovery requests” ordered. Plaintiff's Contested Motion to Strike [ECF No. 134] at 2. The Court is not inclined to grant the sweeping relief Plaintiff demands, especially where Zukowski Defendants were in constant communication with Plaintiff about the delay and were not put on notice by Plaintiff that failure to respond within 30 days of service or file a motion for an extension of time would result in a blanket waiver of their objections. In the exercise of the Court's discretion, therefore, Defendants’ delay in responding to Plaintiff's discovery requests was not unreasonable under the circumstances and does not result in a waiver or forfeiture of valid objections.

*12 For all these reasons, Plaintiff's Motion to Strike Defendants’ Joint Amended Privilege Log [ECF Nos. 93, 132] is denied, both as it pertains to the sufficiency of the privilege log and the “at issue” waiver doctrine. Zukowski Defendants’ Motion to Strike Plaintiff's Discovery Objections and to Compel Plaintiff's Discovery Responses and Motion for Entry of a Protective Order [ECF No. 127] is granted in part and denied in part. Plaintiff's Contested Motion to Compel Production of Mobile Phone for Inspection and Data Collection Pursuant to Written Protocol [ECF No. 122] is denied. Finally, Plaintiff's Contested Motion to Strike Zukowski Defendants’ Discovery Objections and to Compel Zukowski Defendants’ Discovery Responses [ECF No. 134] is granted in part and denied in part.

To the extent the Court has ordered either side to respond further to the other's discovery or to take further action of any kind, that party or those parties shall do so within fifteen (15) days of the date of this Order. If the parties agree to a different date, they shall file a motion and stipulation to that effect and the Court will change the dates.

It is so ordered.