I thought this topic was pertinent:
For every single case, every one, they employ the same stock answer - to each request, they say over and over again, that it is “overly broad, vague and ambiguous”; the information requested is “irrelevant” and will not “lead to the discovery of admissible evidence”. They don’t even bother to vary the wording, it’s just what lawyers call “boilerplate” language, there’s no attempt to argue each point, it’s simply stonewalling.