In response to Document Request Nos. 11 and 12, Sakar alleges that the expense of
compliance with the request would be “substantial. To the extent Sakar is seeking to invoke the
protections of Rule 26(b)(2)(B), however, it has failed to meet its burden of persuasion because
bald generalizations are insufficient. Rather, “the responding party should present details
sufficient to allow the requesting party to evaluate the costs and benefits of searching and
producing the identified sources.”
From DOC 322
