This section contains the nature of the case and procedural background.

Moss (P) brought an action against Blue Cross (D), alleging that D interfered with, restrained, and denied her exercise or attempt to exercise her right to use protected leave under the Family and Medical Leave Act (“FMLA”), 29 U.S.C. 2601 et seq. P filed the present motion seeking to compel responses to Interrogatory Nos. 8, 9, and 10 and production of documents to Request Nos. 2, 3, 7, 8, 13-18, and 20. D objected to interrogatory 8 as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. There was no way to identify the employees other than by reviewing the personnel files of every person who worked for the defendant during the past ten years. That would include thousands of employees. Defendant objected to this interrogatory 9 as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. The interrogatory is unlimited and calls for information throughout the years that D has utilized the referenced policy or one with similar requirements. The only way to identify the employees is by reviewing the personnel files of all current and former employees who worked for defendant while such a policy was in effect. D objects to document request 2 as overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Defendant objects to document request 3 as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. D objects to document request #7 as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. D objects to document request #20 as being overly broad, unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Plaintiff does not assert any claims of sex discrimination (under Title VII or otherwise), age discrimination (under ADEA or otherwise), disability discrimination (under the ADA or otherwise), or any other violation of Title VII. The time for amendment of the pleading has passed. Furthermore, response to the request would require defendant to violate binding contractual confidentiality.

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