Copy of every document produced in the last five years that makes any reference to a racial group.

You have requested to obtain a copy of every document produced in the last five years that makes any reference to a racial group.  Kuaiji has objected claiming that the request is too broad and irrelevant to the case as a whole.  Using Robertson v. People magazines, the judge will likely determine that:

A.  The request cannot be granted, as such documents are protected by editorial privilege

B.  While granting such a request might burden Kuaiji, the relevance of the documents to the case outweighs any such burden.  The discussion of race at an accounting firm is different than the discussion of race by a committee deciding what articles to publish.

C.  The request is irrelevant because it seems information regarding all racial groups and not just Mexican-Americans.  Discovery requests must be narrow and only seek information that the attorney knows will be used in court.

D.  The growth of technology has made it so that producing such documents will not be burdensome for Kuaiji.  However, like the request is Robertson, such a request is irrelevant to the case.