Agricultural & Industrial Corp. v. Chemical Bank

I would grant the protective order striking all the document requests complained of except the corporate minutes of Fertitex, if appellant has them, and the report referred to in Item No. 11. The remaining requests are invalid for lack of specificity. CPLR 3120 (subd [a], par 1, cl [i]) requires that documents sought by discovery be “specified with reasonable particularity”. In Harnett v Skandia Amer. Reinsurance Corp. (60 AD2d 515), this court said: “The items [set forth in the notice] are typically in the form of ‘all documents and other materials including but not limited to, * * *…