Sakar’s
allegation that the information is somehow “irrelevant” and “not within Sakar’s possession,
custody or control” is simply beyond the pale. This is but one example of Sakar’s dilatory
approach to discovery.
Rather than providing substantive responses to e.Digital’s legitimate discovery, Sakar has
interposed baseless, boilerplate objections. Objections to discovery must be made with
specificity, and the responding party has the obligation to explain and support its objections.