REQUESTS FOR PRODUCTION OF DOCUMENTS
10. Produce all statements in your possession, custody or control, whether written, recorded, or in electronic format, including notes or summaries thereof, taken from any person having knowledge of the accident of March 17, 2007 or any matters referred to The Complaint.
Defendant objects to this Request on the grounds that it seeks documents protected by the attorney-client privilege and the work product doctrine. Defendant further objects that this Request is insufficiently limited as to time, scope, and subject matter. This Request is unduly vague, open, and burdensome, in that it potentially seeks documents which are neither relevant nor reasonably calculated to lead to the discovery of admissible evidence.
Notwithstanding the foregoing, see attached correspondence, which purports to be a handwritten letter (in red ink) from Plaintiff to Defendant, dated March 19, 2007, titled "I WILL SUME [sic] YOU!"