*1 For the reasons and to the extent explained in the accompanying statement, plaintiff's motion to compel (Dkt. 33) is granted in part and denied in part. Defendant shall produce the compelled discovery responses by 7/21/22. The parties are directed to meet and confer regarding Interrogatory Nos. 10 and 17, as well as any issues related to defendant's productions pursuant to this order, by 8/4/22. A JSR is due from the parties by 8/18/22, confirming production of this ordered discovery, a list of anticipated depositions with at least some firm, scheduled dates for those depositions, and the parties’ proposed fact discovery deadline.

All of the following allegations are drawn from Plaintiff Willie Forrest's Amended Complaint (“Am. Compl.”), Dkt. 8. Plaintiff is a retired employee of the United States Department of Veterans Affairs. After 24 years as a contracting officer with the VA, in June 2014, plaintiff began a position as a Procurement & Resource Specialist in Hines, IL. Am. Compl. ¶ 23. When he started his new position, his immediate supervisor was Christine Szrom, who had recommended plaintiff for the job. Id. ¶¶ 24-26. Shortly after plaintiff started, however, Szrom took leave and Jane Stroder—Szrom's boss—assumed day-to-day responsibilities for Szrom's team, including Forrest. Id. ¶ 27. Plaintiff alleges that from the first time they met, Stroder was hostile toward plaintiff. Id. ¶ 29. According to plaintiff, during their first encounter, Stroder told him that he was dressed inappropriately even though he was wearing jeans in accordance with office custom for Fridays. Id. ¶¶ 31-32. At their next encounter, at a team meeting where each employee was to report on their work statuses and concerns, Stroder abruptly interrupted plaintiff when it was his turn to speak and ended the meeting. Id. ¶ 33.

Plaintiff alleges that Stroder's hostility continued in the months to come. Plaintiff maintains that Stroder continued to be hostile and dismissive of plaintiff during meetings; she excessively scrutinized his emails for grammar errors in a way that she did not for non-black employees; she increased plaintiff's workload unreasonably, giving him responsibility for an unmanageably large backlog of subcontracting plans; and she privately and publicly harassed plaintiff about his lack of progress when, in reality, plaintiff had not been given access to a database necessary to complete his work. Id. ¶¶ 35-50. In addition, to ensure plaintiff was unable to complete the work assigned to him, Stroder forced plaintiff to send drafts of emails to her husband, another VA employee, who found reasons to reject the emails. Id. ¶¶ 51-54.

Szrom returned to work in January 2015, but things did not improve for Plaintiff. Szrom and Stroder called plaintiff into a meeting that month, and Stroder stood over plaintiff and yelled at him. Id. ¶ 61. When Plaintiff attempted to respond to her, she became enraged and yelled that all she wanted to hear out of his mouth was “yes ma'am and no ma'am.” Id. During the meeting, Stroder made comments about plaintiff's age and perceived disability and Szrom agreed with Stroder. Id. ¶ 62. Szrom and Stroder talked back and forth to one another as though plaintiff was not present, and Szrom stated that she was told not to hire plaintiff but did so against her better judgment. Id. ¶¶ 63-64. Eventually, plaintiff grabbed his chest and agreed to retire if they would give him 30-60 days. Id. ¶ 65. Plaintiff alleges that the meeting was conducted in an area where other employees could hear what was happening in a deliberate effort to humiliate him. Id. ¶¶ 66-67. After the meeting, plaintiff's physician recommended he see a psychiatrist, and plaintiff requested and was granted a leave of absence from work. Id. ¶¶ 70-71. While plaintiff was on leave, Szrom had 6-7 people working on the small business contracting plans that had previously been assigned to plaintiff. Id. ¶ 73. Plaintiff returned to work two months later and was threatened with disciplinary action on the day he returned. Id. ¶¶ 74-75. He received two write-ups and a threat of a performance plan within his first 30 days back at work. Id. ¶ 76. Szrom subsequently sent plaintiff an email asking when he planned to retire. Id. ¶ 78. Szrom continued to nitpick plaintiff's work and claimed that he was not following a non-existent process. Id. ¶¶ 80.

*2 In the fall of 2015, a meeting was scheduled with the EEO Office of Hines Hospital and the African American employees who reported to Stroder. Id. ¶ 82. Stroder, however, retired before that meeting could occur. Id. ¶ 83. In April 2016, plaintiff requested an accommodation to telework for 5 days a week due to his anxiety, stress, and depression. The Local Reasonable Accommodations Coordinator (“LRAC”) assigned to assist with plaintiff's case recommended that Plaintiff be given an interim accommodation while his request was being processed. Id. ¶¶ 86-89. Szrom provided no such interim accommodation. Id. ¶¶ 88-90. After evaluating plaintiff's claim, the LRAC determined that plaintiff was a qualified individual with a disability and recommended he be given a reasonable accommodation. Id. ¶¶ 91-92. Szrom initially offered plaintiff an accommodation of teleworking three days per week for 30 days, with conditions. Id. ¶ 93. Plaintiff accepted these accommodations and fulfilled the conditions, but before the accommodation began, Szrom sent Plaintiff and the LRAC an email instructing him not to begin the accommodation. Id. ¶ 95. According to plaintiff, Szrom made up false reasons why plaintiff could not start the accommodation. Id. ¶ 96. When plaintiff made phone calls and sent emails to Szrom and LRAC asking whether he could start the accommodation, his communications went unanswered. Id. ¶¶ 97-98. After the VA refused to accommodate plaintiff's disability, plaintiff retired.

After a series of administrative proceedings, plaintiff brought the instant complaint, alleging: (1) racial discrimination and hostile work environment based on race, (2) age discrimination and hostile work environment based on age; (3) retaliation based on plaintiff's opposition to racial discrimination in the workplace; (4) retaliation based on plaintiff's opposition to age discrimination in the workplace; (5) unlawful failure to accommodate plaintiff's disability under the Rehabilitation Act; and (6) constructive discharge. Currently before the Court is plaintiff's motion to compel various discovery responses, Dkt. 33.

I. Applicable Legal Standards

Under the Federal Rules of Civil Procedure, “parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(1). “Information within this scope of discovery need not be admissible in evidence to be discoverable.” Id. Rule 26 vests the courts with broad discretion in determining the scope of discovery. See, e.g., Spiegla v. Hull, 371 F.3d 928, 944 (7th Cir. 2004) (The court has “broad discretion over discovery matters.”); KISS Pharm LLC v. Becker Pro. Dev. Corp, No. 18 C 7848, 2021 WL 3207822, at *4 (N.D. Ill. July 29, 2021) (same) (citations omitted). This Court is mindful that the standard for discovery under Rule 26(b)(1) is widely recognized as one that is necessarily broad in its scope in order to allow the parties essentially equal access to the operative facts. Scruggs v. Miller, No. 17 CV 0467, 2019 WL 12261812, at *3 (N.D. Ind. June 26, 2019) (citing Scott v. Edinburg, 101 F. Supp. 2d 1017, 1021 (N.D. Ill. 2000)).

A party may seek an order to compel discovery when an opposing party fails to respond to discovery requests or has provided evasive or incomplete responses. Fed. R. Civ. P. 37(a)(2)-(4) (2018). The burden “rests upon the objecting party to show why a particular discovery request is improper.” Kodish v. Oakbrook Terrace Fire Protection Dist., 235 F.R.D. 447, 449-50 (N.D. Ill. 2006). The objecting party must show with specificity that the request is improper. Graham v. Casey's Gen. Stores, 206 F.R.D. 251, 254 (S.D. Ind. 2002). 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 v. Mitsubishi Motors, Corp., No. 04 CV 4932, 2006 WL 2325506 at *6 (N.D. Ill. 2006) (internal citations omitted). “Before restricting discovery, the court should consider the totality of the circumstances, weighing the value of the materials sought against the burden of providing it, and taking into account society's interest in furthering the truth-seeking function in the particular case before the court.” Patterson v. Avery Dennison Corp., 281 F.3d 676, 681 (7th Cir. 2002) (internal quotation and citation omitted).

II. Discussion

A. Defendant's Initial Disclosures

*3 Plaintiff moves to compel production of certain information that he says defendant should have produced as part of its initial disclosures. Defendant's initial disclosures at first identified both specific witnesses whom defendant indicated possessed relevant knowledge as well as certain groups of unidentified individuals, including “[a]ny and all individuals identified in the administrative record.” Mot. Tab A, Dkt. 33-1 at 3. Defendant's disclosures did not list contact information for the unspecified individuals identified in the administrative record. When plaintiff requested contact information for those individuals, defendant amended its initial disclosures to remove the reference to individuals identified in the administrative record. See Mot. Tab A at 4-5. Plaintiff now moves to compel defendant to provide contact information for the individuals identified in the administrative record.

Plaintiff's motion is denied. Federal Rule of Civil Procedure 26(a)(1)(A)(i) requires parties to disclose “the name and, if known, the address and telephone number of each individual likely to have discoverable information ... that the disclosing party may use to support its claims or defenses ...” (emphasis added). By its express terms, the rule does not require parties to disclose the name and contact information of all witnesses with relevant information; the rule requires only disclosure of witnesses that the disclosing party may use to support its position. See City of Chicago v. Purdue Pharma L.P., No. 14 CV 4361, 2017 WL 2819948, at *2 (N.D. Ill. Mar. 3, 2017) (“Rule 26(a)(1)(A)(i) requires the identification only of persons whom a party ‘may use’ to support its claims or defenses, not everyone with knowledge about the subject matter.”). If defendant does not intend to use the witnesses identified in the administrative record at trial, then it need not disclose contact information for those witnesses. While the Court recognizes plaintiff's frustration that defendant removed the unidentified witnesses from its disclosures instead of identifying them and providing contact information, nothing in the Federal Rules of Civil Procedure barred defendant from making that choice. The risk defendant runs is that to the extent it wishes to call at trial individuals identified in the administrative record who are not specifically identified in its amended disclosures, it may not be permitted to do so. But there is no basis to compel disclosure of contact information for any unidentified witnesses on the record now before the Court.

Plaintiff also takes issue with defendant's disclosures with respect to specifically identified current VA employees. In both its initial and amended disclosures, defendant noted that the current VA employees could be contacted through defendant's counsel. Plaintiff disputes that those witnesses are in fact represented by defendant's counsel and requests an order compelling disclosure of their contact information. In response, defendant has agreed to provide contact information for current employees, but reiterates that they are represented by counsel. Because defendant has agreed to the relief requested, the motion is denied as moot with respect to the specifically identified current VA employees. Although the Court cannot weigh in on the current record regarding whether those employees are in fact represented by defendant's counsel, plaintiff's counsel should take seriously defendant's representation that they are so represented and should conduct appropriate investigation prior to contacting them via an appropriate method.

B. Defendant's Interrogatory Responses

Interrogatory No. 1: Interrogatory No. 1 requests the identity of the person(s) who were consulted in any way in responding to the interrogatories and to identify the interrogatories to which the person contributed. Mot. Tab B, Dkt. 33-2 at 6-7. Defendant responded by pointing to the verification page at the end of their amended interrogatory responses, which was signed by an individual named Craig Robinson. Def's Resp. to Mot. to Compel (“Resp”), Ex. 2, Dkt. 38-2 at 3, 10. Plaintiff maintains that this is an incomplete response because Robinson has no first-hand knowledge of the subject matter of the interrogatories and because his verification indicates that “the foregoing are based on information and documents provided by agency employees and/or former employees.” Id. Defendant insists that it has provided a complete response to plaintiff's interrogatory, (Resp. at 10), but the Court disagrees. The interrogatory requests information about individuals who were consulted in preparing interrogatories and to identify the interrogatories to which they contributed; the verification to which defendant points admits that there are unidentified individuals who furnished factual information used to respond to interrogatories. A complete response must identify those individuals and the interrogatories for which they furnished relevant information; defendant has provided no such response to date.

*4 Defendant cites a case that it says stands for the proposition that interrogatories seeking to identify persons who participated in preparing answers to interrogatories is improper. See Resp. at 10 (citing Bd. of Educ. of Evanston Twp. High Sch. Dist. No. 202, Cook Cty., Ill. v. Admiral Heating & Ventilating, Inc., 104 F.R.D. 23, 32 (N.D. Ill. 1984)). Defendant's reliance on Evanston Township is misplaced for two reasons, however. First, in that case, the Court was addressing an objection under the work product doctrine, but defendant here did not lodge any work product objection to Interrogatory No. 1. See Resp. Ex. 2 at 3. Second, even assessing the request under a work product framework, the Evanston Township court distinguished between the identities of individuals who furnished information used in preparing interrogatory responses—which it suggested were discoverable—and the identities of those who actually drafted the interrogatory responses, which the court indicated were protected from disclosure by the work product doctrine. Evanston Twp., 104 F.R.D. at 32. Defendant has not provided information regarding the individuals who furnished the factual information used to respond to each interrogatory. Defendant must do so. Plaintiff's motion is granted with respect to Interrogatory No. 1.

Interrogatory Nos. 2 and 3: Interrogatory No. 2 asks that the defendant identify each employee employed at the Federal Supply Schedule Services in Hines, IL between January 1, 2014 and December 31, 2018 that reported to Christine Szrom at any time during that period. Defendant objected to Interrogatory No. 2 on the grounds that “it is irrelevant to any parties’ claims or defenses and disproportionate to the needs of the case.” Resp. Ex. 2 at 3. Interrogatory No. 3 requested the race, age, and disability status of each of the employees identified in response to Interrogatory No. 2. Defendant made the same boilerplate objection that it did to Interrogatory No. 2, but it also noted that the Privacy Act barred disclosure of the requested disability information. Defendant then provided the age and race of six of plaintiff's coworkers. Id. at 4.

Plaintiff moves to compel complete responses to Interrogatory Nos. 2 and 3. Plaintiff argues that information about potential comparators is relevant in this employment discrimination case. Defendant's response with respect to Interrogatory No. 2 is unclear; defendant groups its response to Interrogatory No. 2 with its response to Interrogatory No. 3, and only appears to address the disability status portion of Interrogatory No. 3. Resp. at 8. Even if defendant had made a clear response to plaintiff's motion with respect to Interrogatory No. 2, however, the Court would find that any such argument was waived. The entirety of defendant's response to Interrogatory No. 2 consisted of a rote, boilerplate objection that the requested information is irrelevant and disproportionate to the needs of the case. Resp. Ex. 2 at 3. “Time and time again, attorneys are warned that boilerplate objections are unacceptable. They are tantamount to not making any objection at all.” Saleh v. Pfister, No. 18 C 1812, 2020 WL 4365641, at *1 (N.D. Ill. July 30, 2020) (collecting cases). In addition, in setting a due date for defendant's response brief, the Court specifically instructed defendant to explain why its repeated use of unexplained boilerplate objections did not constitute a waiver of its objections to plaintiff's discovery requests, and to the extent defendant asserted that responding to any particular discovery request would be unduly burdensome, defendant had to explain in detail and quantify its burden. Dkt. 34. Despite the Court's express order, defendant did not address the import of its use of boilerplate objections. Therefore, the Court now finds that the defendant has waived its objections to Interrogatory No. 2, and must identify the individuals who reported to Szrom during the identified period. See Saleh, 2020 WL 4365641, at *1 (“The boilerplate answer constituted a waiver of whatever objection, if any, [Defendant] might properly have made. Boilerplate objections, as we have shown, are ineffectual in all contexts.”).[1] In addition, this information is relevant because it will enable plaintiff to assess potential comparators, rather than simply relying on the list of six employees whom defendant has identified. Nor is the Court convinced that this request for discrete pieces of information is so facially overbroad that granting the request notwithstanding defendant's waived objections would be oppressive or punitive to the Defendant.

*5 Likewise, with respect to Interrogatory No. 3, defendant must identify the race and age of all of the individuals defendant now identifies in response to Interrogatory No. 2. Defendant's only objections with respect to those elements of Interrogatory No. 3 are the same boilerplate that defendant lodged against Interrogatory No. 2. And the requested race and age information is plainly calculated to lead to the discovery of relevant information, as it identifies the universe of potential comparators for plaintiff's age and race discrimination claims.

By contrast, plaintiff has not made a threshold showing that the requested information in Interrogatory No. 3 regarding VA employees’ disabilities is relevant to this matter. As defendant notes, plaintiff's claims related to his disabilities concern defendant's alleged failure to accommodate plaintiff's disabilities by allowing him to telework full time; he does not maintain that defendant engaged in disparate treatment of plaintiff due to his disabilities. To prevail on a failure to accommodate claim under the Rehabilitation Act, plaintiff must show (1) he was a qualified individual with a disability, (2) defendant was aware of his disability, and (3) defendant failed to reasonably accommodate his disability. Sansone v. Brennan, 917 F.3d 975, 979 (7th Cir. 2019). Plaintiff has not explained how the requested comparator evidence is relevant to defendant's alleged failure to accommodate his disabilities. Plaintiff's motion is therefore granted with respect to Interrogatory No. 2 and with respect to the race and age components of Interrogatory No. 3.[2]

Interrogatory Nos. 4 and 5: Interrogatory No. 4 asks defendant to “[i]dentify all the employees who worked at the Office of Acquisition & Logistics (OAL), National Acquisition Center (NAC), Veterans Administration Federal Supply Schedule Services (VAFSSS) in Hines, IL from January 1, 2014 through December 31, 2018 who were telecommuting/teleworking.” Mot. Tab B. at 7. The request also asks for a variety of information about each such employee, including whether the ability to telework was requested as a result of a request for a reasonable accommodation, who approved the request to telework, and how many days of the week each individual teleworked. Id. at 7-8. Moreover, the request sought the name of all persons whose telework requests were denied and copies of all documents submitted or issued in connection with the request, approval and termination of a telework request for each identified employee. Id. Interrogatory No. 5 asked defendant to identify employees who were approved to telework, for whom the request did not involve a reasonable accommodation request, and asked the defendant to provide the reasons other than a request for a reasonable accommodation that a person would have been approved to telework from January 1, 2014 to December 31, 2018. Id. Defendant made its boilerplate relevance and proportionality objections to both interrogatories, and also objected that Interrogatory No. 4 called for information protected by the Privacy Act. Id.

*6 Plaintiff now moves to compel responses to parts of Interrogatory Nos. 4 and 5. Specifically, plaintiff seeks to compel defendant to identify the employees from the identified VA offices in Hines, IL who were telecommuting/teleworking and to identify whether the telework was approved as a result of an accommodation, the individual who approved the request, and how many days per week each person teleworked. Plaintiff also asks that defendant identify the employees who were approved to telework for reasons other than a reasonable accommodation.

Defendant provides more detail in response to plaintiff's motion than it did in its interrogatory responses. Defendant maintains that telework was available for all of plaintiff's coworkers after a year of service if they could show that they were meeting performance expectations, and so individualized descriptions of who was and was not teleworking is unlikely to bear on the parties’ claims or defenses. Defendant also argues that plaintiff needs to confine his request to potential comparators. The problem with these arguments is that defendant waived them by making only unexplained, boilerplate interrogatory objections with none of the foregoing detail. Saleh, No. 18 C 1812, 2020 WL 4365641, at *1. Indeed, some of the information that defendant now provides in opposing the motion to compel would have been at least partially responsive to plaintiff's interrogatories, but defendant did not amend its interrogatory responses to include this response and an accompanying, more robust objection.

Moreover, with respect to these specific requests, Plaintiff has made a threshold showing that the requested information is calculated to lead to the discovery of relevant information. One of plaintiff's central complaints is that his request to telework was rejected by Szrom, even after he was deemed a qualified individual with a disability; if coworkers of a different race or age were treated differently, and permitted to telework even absent a disability, that would bear on plaintiff's claims that he was discriminated against on account of his race or age. Moreover, the request is relevant to plaintiff's failure to accommodate claim because it bears on the feasibility of his requested accommodation; if dozens of plaintiff's coworkers were teleworking five days a week, that lends support to plaintiff's position that the VA could have accommodated plaintiff's request.[3] Nor is the request so facially overbroad that granting plaintiff's motion would place unreasonable burdens on the defense. The request as narrowed by the motion to compel is for fairly discrete pieces of information regarding a specific accommodation or privilege granted to certain employees. Although the Court agrees with the defendant that there may be narrower requests that could accomplish the same ends, the Court will not rewrite defendant's discovery responses to encompass those more specific objections. Plaintiff's motion is granted with respect to the requested information from Interrogatory Nos. 4 and 5.

Interrogatory Nos. 6-8: Interrogatory No. 6 asks defendant to “[i]dentify the person(s) assigned responsibility for the small business subcontracting plans after plaintiff separated in June 2016,” and to provide a copy of the position description for each such person. Mot. Tab. B at 8. Interrogatory No. 7 asks who succeeded plaintiff in the position of Procurement and Resources Specialist. Id. Interrogatory No. 8 asks defendant to “[d]escribe, in detail, any and all changes, if any to the Procurement and Resources Specialist position after June 2016,” and to provide a copy of the position description. Id. Defendant provided its boilerplate relevance and proportionality objection to each interrogatory, and identified Nicole Stephens as plaintiff's replacement in response to Interrogatory Nos. 6 and 7. Resp. Ex. 2 at 5. Defendant also noted that Stephens is employed by the VA and can be contacted through defendant's counsel. Id.

*7 Plaintiff first moves to compel contact information for Stephens, which he says should have been included pursuant to the definition of “identify” in plaintiff's interrogatories. Defendant indicates that it will provide contact information for current VA employees with the understanding that they are represented by defendant's counsel. Because defendant has agreed to provide the information sought, plaintiff's motion is denied as moot with respect to this issue. Plaintiff's counsel is again reminded to take seriously defendant's representation that current VA employees are represented by defense counsel.

Plaintiff also moves to compel substantive responses to Interrogatory Nos. 7 and 8. Plaintiff notes that although defendant identified Stephens as plaintiff's replacement in response to Interrogatory No. 7, defendant did not indicate that Stephens has the title Procurement and Resources Specialist. And defendant failed to respond to Interrogatory No. 8, aside from its boilerplate objections. Defendant's response brief does not address these issues. Plaintiff's motion is granted with respect to Interrogatory Nos. 7 and 8. One of plaintiff's core allegations is that his supervisors made his workload intolerable; if, for example, his responsibilities were diffused among multiple people after his departure, or if the nature of the position otherwise significantly changed, that would be relevant to plaintiff's claim that he was targeted by his supervisors. Defendant is directed to inform plaintiff who currently holds plaintiff's former title as Procurement and Resources Specialist, and to fully respond to Interrogatory No. 8.

Interrogatory Nos. 9 and 11: Interrogatory Nos. 9 and 11 request information about the process through which plaintiff's reasonable accommodation request was evaluated. In response to those requests, defendant asserted attorney client privilege over three emails to attorney Janet Kyte of the Office of Chief Counsel from Szrom and the LRAC, who determined plaintiff was a qualified individual with a disability. Plaintiff asks the Court to review the emails in camera, attaching an email from Kyte in which she indicated she could not recall whether she was consulted during plaintiff's reasonable accommodation process. See Mot., Am. Tab F, Dkt. 36-1. The Court declines plaintiff's invitation to review the documents in camera. Kyte's email explained that Designated Management Officials who believe a request for accommodation should be denied must consult with the Office of Chief Counsel or the National Reasonable Accommodation Coordinator prior to issuing the denial, and also notes that the OCC serves as a legal expert on matters pertaining to accommodation requests. Given the nature of Kyte's job and the explanation provided in her email, the fact that Kyte did not recall whether she was consulted regarding plaintiff's specific request does not cast meaningful doubt on defendant's assertion of privilege.

Interrogatory Nos. 10 and 17: Interrogatory No. 10 requests: “From January 1, 2013 through the present, identify any employee employed at the VAFSSS in Hines, IL where Christine Szrom and/or Jane Stroder were their first or second line supervisor and the employee was disciplined in any way because of their work performance or terminated for work performance. (For each employee identified, provide copies of their personnel, disciplinary and performance evaluation files).” Mot. Tab B at 9. Interrogatory No. 17 asks defendant to “[s]tate whether defendant has any knowledge of any complaints made against Christine Szrom or Jane Stroder, including complaints made to Hines Hospital during the time period of January 2013 to the present? If your response is ‘Yes,’ then explain in detail each complaint.” Id. at 11. The request also asks for a copy of the complete file for each such complaint. Id. The government issued its boilerplate relevance and proportionality objection to Interrogatory No. 10, and objected that Interrogatory No. 17 was ambiguous and disproportionate to the needs of the case. Resp. Ex. B at 6, 8. Defendant also indicated in its response filing that it searched for all prior EEO complaints filed against the VA with either Stroder or Szrom listed as the responsible management official; defendant identified one such complaint. Id. at 8.

*8 In assessing these interrogatories, the Court confronts competing concerns brought about by the parties’ less than fulsome approach to resolving disputes in this matter and talking past each other to a large extent in the briefing. On the one hand, as noted repeatedly above, defendant has failed to preserve its objections by submitting perfunctory, boilerplate objections in response to plaintiff's discovery requests. Resp. Ex. B at 6, 8. On the other hand, the two requests at issue here are exceedingly broad, essentially asking for all complaints against Stroder and Szrom (irrespective of the complainant, the nature of the complaint, or whether the complaint was written or oral, or formal or informal) for a nearly decade-long period, as well as all discipline issued by Szrom or Stroder over the same relatively long period and copies of full personnel files for any disciplined employee. As defendant notes in its response brief (but not in its discovery objections), compiling this information would likely require painstaking efforts by the defendant and much of the information gathered would likely have limited utility to this litigation. Moreover, plaintiff has done little to justify the breadth of these requests, devoting just a few sentences to them and asserting in conclusory fashion that the requests will capture relevant information. (Mot. at 8.) It seems likely that some of the information captured by Interrogatory Nos. 10 and 17 may be relevant to plaintiff's claims[4]—just as some responsive information would be relevant if plaintiff requested every document generated at the Hines, IL VA facility from 2013 to present. But the Court nonetheless concludes that, unlike the other requests for which defendant submitted only boilerplate objections, these requests are so facially overbroad that the Court will exercise its discretion to deny plaintiff's motion on these interrogatories at this juncture.

The Court will, however, direct the parties to meet and confer regarding any appropriate subset of the requested information that should be produced. As defendant concedes, discovery of disciplinary files may be appropriate if tailored to potential comparators who are similarly situated to plaintiff, Resp. at 5-6. So too may certain kinds of complaints against Stroder and Szrom be relevant and proportional to the needs of this case, even if they did not rise to the level of a formal EEO complaint. While the Court will not do the parties’ work to tailor discovery requests, responses, or objections for them, given the posture with respect to these interrogatories, the Court will not foreclose plaintiff from discovering a narrower subset of the requested information after an appropriate meet and confer. And the parties must take into account proportionality concerns when negotiating more narrow discovery requests. Any further discovery motions based on overbroad requests will be summarily denied, without an opportunity to pursue a narrower subset of information.

C. Defendant's Responses to Requests for Production

Finally, plaintiff seeks to compel defendant to amend its responses to requests for production to identify which documents are responsive to each individual request for production. Plaintiff's motion is denied with respect to this issue. Plaintiff cites Federal Rule of Civil Procedure 34(b)(2)(B) in support of his position, but nothing in Rule 34(b)(2)(B) supports the proposition that responses to requests for production must identify which documents are responsive to each individual request. The Rule merely indicates 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.” Fed. R. Civ. P. 34(b)(2)(B). Rule 34(b)(2)(B) continues that “[t]he responding party may state that it will produce copies of documents or of electronically stored information instead of permitting inspection,” and that “production must then be completed no later than the time for inspection specified in the request or another reasonable time specified in the response.” Id. By its plain terms, Rule 34(b)(2)(B) requires only that a party state that it will produce copies of documents in its responses to requests for production; it does not require a party to identify the Bates range of documents responsive to each request.

*9 Nor is it general practice for parties in litigation to necessarily do so. As defendant argues, if plaintiff wanted defendant's discovery responses to include this categorized information, plaintiff could have negotiated that with defendant in advance, particularly given the large volume of documents that the Defendant has already produced to date. Indeed, the relevant rule appears to be Fed. R. Civ. P. 34(b)(2)(E), which provides that a “party must produce documents as they are kept in the usual course of business or must organize and label them to correspond to the categories in the request” (emphasis added.) Plaintiff has not made a showing that defendant's documents were produced other than the way they are kept in the usual course of business, and therefore has not demonstrated that he is entitled to relief under Rule 34.

III. Conclusion

For the foregoing reasons, plaintiff's motion to compel (Dkt. 33) is granted in part and denied in part.[5]