*1 On July 20, 2015, Magistrate Judge William V. Gallo entered an order requiring Defendant Costco Wholesale Corporation (“Costco”) to fully respond to certain interrogatories and requests for production of documents (“RFP”) to which Costco had objected. [Doc. No. 33.] On August 6, 2015, Costco filed objections to Judge Gallo's order. [Doc. No. 37.] Plaintiff has opposed Costco's objections, and Costco filed a reply. As discussed below, Costco's objections are overruled.

I. Background

The parties brought a dispute about numerous RFP's and Interrogatories to Magistrate Judge Gallo. Upon review of the discovery requests and Costco's responses and objections thereto, and after conducting a discovery conference, Judge Gallo issued a tentative ruling overruling Costco's boilerplate objections and conditional responses because they violated the intent of the Federal Rules, case law, and Judge Gallo's chambers rules, which explicitly state that boilerplate plate objections are inadequate and that “conditional responses ... are improper and ultimately have the effect of waiving ... objections to the discovery requests.” Judge Gallo then gave Costco the opportunity to file a brief supporting the validity of its objections.

After receiving Costco's brief, Judge Gallo issued a formal order affirming his tentative ruling that Costco's objections to the disputed discovery requests were waived, with the exception that objections on the basis of attorney-client privilege or work product will not be deemed waived so long as Costco provides a privilege log compliant with Federal Rule of Civil Procedure 26. The ruling also states that “none of Plaintiff's discovery requests are irrelevant or not reasonably calculated to lead to the discovery of admissible evidence, as Defendant argues.”

II. Legal Standards

District court review of magistrate judge orders on non-dispositive motions is limited. A motion relating to discovery, such as the motion at issue here, is considered non-dispositive. See 28 U.S.C. § 636(b)(1)(A). A district court judge may reconsider a magistrate judge's ruling on a non-dispositive motion only “where it has been shown that the magistrate's order is clearly erroneous or contrary to law.” Id.; see also Fed. R.Civ. P. 72(a). “The ‘clearly erroneous’ standard applies to the magistrate judge's factual determinations and discretionary decisions ....” Computer Econ., Inc. v. Gartner Grp., Inc., 50 F.Supp. 2d 980, 983 (S.D. Cal. 1999). “Under this standard, ‘the district court can overturn the magistrate judge's ruling only if the district court is left with the definite and firm conviction that a mistake has been made.’ ” Id. (quoting Weeks v. Samsung Heavy Indus. Co., Ltd., 126 F.3d 926, 943 (7th Cir. 1997)); see also Concrete Pipe & Products of California, Inc. v. Constr. Laborers Pension Trust for S. California, 508 U.S. 602, 623 (1993) (“[R]eview under the “clearly erroneous” standard is significantly deferential, requiring a “definite and firm conviction that a mistake has been committed.”).

*2 “The ‘contrary to law’ standard, however, allows independent, plenary review of purely legal determinations by the Magistrate Judge.” Jardin v. DATAllegro, Inc., No. 10-CV-2552-IEG WVG, 2011 WL 3299395, at *2 (S.D. Cal. July 29, 2011) (internal quotations omitted). “A decision is contrary to law if it fails to apply or misapplies relevant statutes, case law, or rules of procedure.” Dish Network, L.L.C. v. Sonicview USA, Inc., No. 09-CV-1553-L WVG, 2012 WL 4848957, at *1 (S.D. Cal. Oct. 11, 2012) (citation omitted).

III. Discussion

Costco's main (if not only) argument is that its objections to Plaintiff's discovery requests were adequate because the discovery requests themselves were not sufficiently particular. For the most part, Costco does not dispute that its responses violated Judge Gallo's chambers rules, or argue that Judge Gallo lacks the authority to issue such rules setting parameters for discovery in the cases before him. Thus, without saying as much, Costco effectively asks the Court to hold that Judge Gallo's chambers rules governing objections to discovery requests are “contrary to the law.” The Court declines to do so.

In any event, although Judge Gallo may have phrased his ruling as a determination that Costco had “waived” its objections, and based that ruling in part on Costco's violation of his chambers rules, the ultimate outcome is that Costco's boilerplate objections were overruled. There ample authority for the proposition that boilerplate objections are improper. See, e.g., Dolarian Capital, Inc. v. SOC, LLC, No. 1: 11-CV-0031-LJO, 2012 WL 4026818, at *2 (E.D. Cal. Sept. 12, 2012) (Rule 34 “requires that a party responding to a request for production must either state that inspection of documents and related activities will be permitted as requested, or state an objection, including the specifics of the objection and how that objection relates to the documents being demanded. Generic, boilerplate objections to discovery are not sufficient.”) (internal citations omitted) (citing cases). Along these lines, “[a] recitation that the discovery request is ‘overly broad, burdensome, oppressive and irrelevant’ is not adequate to voice a successful objection.” Hall v. Tehrani, No. C 09-0057 RMW PR, 2011 WL 3267759, at *1 (N.D. Cal. July 29, 2011). Rather, “[a]n objecting party must make some showing that the interrogatory [or request] is unduly burdensome or overly broad.” Rogers v. Giurbino, 288 F.R.D. 469, 487 (S.D. Cal. 2012).

In its responses, Costco utilizes the same two sentences at the beginning of its responses to each disputed RFP: “Costco objects to the extent this request seeks information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Costco objects to this request on the grounds that it is vague, ambiguous, overbroad, and unduly burdensome.” These two sentences are the epitome of boilerplate objections, and Judge Gallo's order was not contrary to the law to the extent it overruled these objections on that basis alone.[1] However, that is not the only basis on which Judge Gallo overruled these objections. Rather, Judge Gallo specifically found that “none of Plaintiff's discovery requests are irrelevant or not reasonably calculated to lead to the discovery of admissible evidence, as Defendant argues.” This factual finding was not clearly erroneous and therefore is another basis on which this Court overrules Costco's objections to Judge Gallo's order.[2]

*3 Likewise, Costco utilizes the same two sentences at the end of its paragraph of objections to each disputed RFP: “Costco further objects to the extent the request seeks private information or confidential business information. Costco further objects to the extent this request calls for disclosure of information protected by the attorney-client privilege or attorney work-product doctrine.” These two sentences are also boilerplate. Moreover, requiring a party to provide a privilege log to maintain a claim of privilege or work product protection, as Judge Gallo does in his order, is consistent with, not contrary to, the law.[3] Accordingly, Judge Gallo's order was not contrary to the law insofar as it overruled these objections.[4]

This leaves just one remaining objection, which Costco asserted in response to all but three of the RFP's, and both interrogatories: “Costco further objects that, at this juncture, the [request/interrogatory] is overbroad and premature as no class has been certified.” Although the Court finds this objection marginally more specific than the others, Judge Gallo's order overruling it was not contrary to the law. As the Ninth Circuit has held:

*4 Vinole v. Countrywide Home Loans, Inc., 571 F.3d 935, 942 (9th Cir. 2009). Thus, there is no hard and fast rule prohibiting class discovery before class certification. If anything, Vinole indicates a preference for allowing such discovery. In overruling Costco's objection that the discovery was not proper because no class has been certified, Judge Gallo simply exercised the district court's discretion to allow class discovery prior to class certification. Judge Gallo's order was not an abuse of that discretion, and therefore was not contrary to the law or clearly erroneous insofar as it overruled this objection.

IV. Conclusion

For the foregoing reasons, Costco's objections to Judge Gallo's July 20, 2015 Order are OVERRULED. On or before October 21, 2015, Costco shall (1) serve its responses to the disputed interrogatories, (2) make the remaining responsive documents to the disputed requests available for inspection and copying by Plaintiff, and (3) serve any privilege log consistent with Judge Gallo's order.

It is SO ORDERED.

In its brief to this Court, Costco implausibly complains that responding to the disputed RFP's would be unduly burdensome because it would require tens of thousands of attorney hours. Costco does itself no favors by making these hyperbolic arguments as they undermine its entire position. There is no requirement that Costco search every single file and hard drive in its possession for possible responsive documents. Rather, Costco must conduct a good faith reasonable search of the places where responsive documents are likely to be located. Costco, not Plaintiff, is in the best position to identify where those documents might be within Costco's files. Nor is there any requirement that Costco search every single email on its servers without using reasonable search terms intended to capture any responsive documents or preventing Costco from limiting its search to custodians who may have responsive documents. Nor is Costco under any obligation to have attorneys lay eyes on every one of the thousands of documents it claims are responsive, particularly when, as appears to be the case here, it is unlikely that the most of the categories of documents sought would contain privileged material. Nor is Costco under any obligation to convert “Roadnet” records into a reviewable format, let alone pay 13,000 billable attorney hours to do so (assuming the attorneys even had such capabilities). If these Roadnet records are in fact responsive and Plaintiff actually wants them, Costco can make them available for Plaintiff to copy in native format and Plaintiff can deal with converting them into readable form. Ultimately, Costco need only make the requested documents available to Plaintiff for inspection and copying. The Court is confident that Costco can comply with this requirement without spending even two percent of the over 25,000 hours it claims would be necessary.

Costco also objects to both disputed interrogatories as seeking “information that is irrelevant and not reasonably calculated to lead to the discovery of admissible evidence.” For the same reasons, Judge Gallo's order was not contrary to the law or clearly erroneous in overruling this objection to the interrogatories.

Costco fleshes out the basis for its privacy objection in its brief to this Court, arguing that the information sought might violate the privacy rights of the putative class members. However, “[i]n the context of a class action, disclosure of basic contact information for putative class members is ‘common practice’ and does not constitute a serious invasion of privacy, particularly when the Court determines they may possess relevant discoverable information about class certification issues and the other allegations in plaintiff's Complaint. Defendant's request to protect the privacy of contact information of its employees or former employees must therefore yield to plaintiff's need for this information to pursue his theory of the case and to determine whether he can support a motion for class certification.” Hernandez v. Best Buy Co., No. 13CV2587-JM KSC, 2014 WL 5306888, at *9 (S.D. Cal. Oct. 15, 2014) (citing Artis v. Deere & Co., 276 F.R.D. 348, 353 (N.D. Cal. 2011).

RFP 3 also includes the boilerplate objection: “Costco further objects that this request assumes facts not in evidence.” For the same reasons, Judge Gallo's order overruling this objection was not contrary to the law.