Judge Peck sends a warning shot to the bar about meaningless, repetitive boilerplate responses to document requests. Judge Peck, in essense, tells counsel to RTFR (a Chris Dale acronym meaning read the F(abulous) Rules and to update their template responses to include specific answers to requests. Unless objections observed the “requirement to state objections with specificity”, he would consider boilerplate objections as waivers to all but privilege claims.
Fischer v Forrest, 2017 U.S. Dist. LEXIS 28102 (S.D.N.Y. Feb. 28, 2017)