Page:Touhy v. Walgreen Company.pdf/15

 Plaintiff, Whitlock, or the litigation or the allegations, facts and circumstances concerning the litigation,” is overly broad. Under our rules, parties to civil litigation are given broad discovery privileges. But with those privileges come certain modest obligations, one of which is the duty to state discovery requests with "reasonable particularity." Fed. R. Civ. P. 34(b)(1)(A). All-encompassing demands of this kind take little account of that responsibility. Though what qualifies as "reasonabl[y] particular" surely depends at least in part on the circumstances of each case, a discovery request should be sufficiently definite and limited in scope that it can be said "to apprise a person of ordinary intelligence what documents are required and [to enable] the court . . . to ascertain whether the requested documents have been produced." Wright & Miller, 8A Federal Practice and Procedure § 2211, at 415. We cannot disagree with the district court that Ms. Touhy's kitchen sink request failed to meet this standard. See id. at 416-17 n.16 (collecting cases involving similar requests held to be overbroad); Manual for Complex Litigation § 11.443, at 75 ("In overseeing document production, the court should . . . prevent indiscriminate, overly broad, or unduly burdensome demands . . . such as those for 'all documents relating or referring to' a . . . claim . . . ."). (continued...) - 15 -