FEARLESS TIES 4, LLC
v.
BRYAN S. JOHNSON, ET AL.
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The court held that defendants' objections to discovery requests were waived or overruled due to lack of specificity and boilerplate language, and granted the motion to compel.
[1] Failure to state grounds for an objection to discovery requests waives those objections.
[2] Boilerplate objections to discovery requests that do not state grounds with specificity violate local rules.
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Join FLexlaw to unlock all legal intelligence“Any ground not stated in an objection within the time provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be waived.”
Establishes that failure to state specific grounds for discovery objections results in waiver of those objections under Local Rules.
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Join FLexlaw to unlock all legal intelligencePlaintiff filed a motion to compel discovery responses from defendants. Defendants' objections were largely boilerplate, lacked specificity, or were w…
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replied. [fn 1] DE 45; DE 51; DE 52. The Court has carefully considered the briefing and the record and is otherwise fully advised in the premises.
The Court set a hearing on the Motion to Compel for January 26, 2026, at 10:30 a.m. DE 44. However, upon review of the briefing, the Court concludes that a hearing is unnecessary to resolve the Motion to Compel. The Court therefore CANCELS the January 26 hearing. For the following reasons, the Motion to Compel [DE 45] is GRANTED.
Plaintiff asks the Court to compel Defendants' full responses to Request for Production #'s 2, 3, 6, 8, 12, 13, and 19 and full answers to Interrogatory #'s 4, 5, and 6. Defendant Koutsodontis did not object to Request for Production #'s 2 and 3. DE 45-2 at 3. Defendant Johnson's response to Request for Production # 2 stated that the Request “is objected to on the
grounds that," but the response then cut off, such that Defendant Johnson did not provide any ground for objection. Id. at 24. Defendant Johnson did not object to Request for Production # 3. Id. Having failed to provide any grounds for objections, any objections are waived under this District's Local Rules, and Defendants must fully respond to Request for Production #'s 2 and 3. See S.D. Fla. L.R. 26.1(e)(2)(A) (“Any ground not stated in an objection within the time provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be waived.").
Defendants' objections to the remaining Requests for Production that are at issue (Request for Production #'s6, 8, 12, 13, and 19) are wholly boilerplate objections that violate the Local Rules because they do not state with specificity the grounds for objection. DE 45-2 at 4–5, 7, 25– 26, 28; see S.D. Fla. L.R. 26.1(e)(2)(A) (“Where an objection is made to any interrogatory or subpart thereof or to any production request under Federal Rule of Civil Procedure 34, the objection shall state with specificity all grounds.”). To the extent Defendants objected based on confidentiality, confidentiality alone is not a basis to withhold discovery. See Adelman v. Boy Scouts of Am., 276 F.R.D. 681, 692 (S.D. Fla. 2011) (“It is well settled that there is no absolute privilege for trade secrets or other confidential information.” (quotation marks omitted)); Kaye v. Fountaine Pajot, S.A., No. 07-61284-CIV, 2008 WL 11422469, at *3 n.4 (S.D. Fla. Jan. 7, 2008) (noting that "it is well settled that confidentiality does not act as a bar to discovery and is generally not grounds to withhold documents from discovery” (quotation marks omitted)). If the parties seek entry of a Confidentiality Order, they must confer on the language of such an Order and move for its entry. Defendants' objections to Request for Production #'s6, 8, 12, 13, and 19 are overruled, and Defendants must fully respond to those Requests.
Defendants objected to Interrogatory #'s 4 and 5 based on irrelevance, overbreadth, and burdensomeness. DE 45-2 at 11, 32. Those Interrogatories ask for information about Hits Only
Music Entertainment, LLC's (“Hits Only”) revenue and intellectual property and are directly relevant to Plaintiff's allegations that Defendant misled Plaintiff about Hits Only's assets in order to induce Plaintiff to invest in Hits Only. E.g., DE 16 ¶¶ 39–50 (allegations in the Amended Complaint). To the extent that Defendants believe the Interrogatories are answered through documents produced to Plaintiff, Defendants may point Plaintiff to the specific responsive documents. Defendants' objections to Interrogatory #'s 4 and 5 are overruled, and Defendants must fully answer those Interrogatories.
Finally, Defendant Koutsodontis' objections to Interrogatory # 6 are wholly boilerplate objections that violate the Local Rules because they do not state with specificity the grounds for objection. DE 45-2 at 11; see S.D. Fla. L.R. 26.1(e)(2)(A). Defendant Johnson provided some information to substantiate his overbreadth objection. DE 45-2 at 32. Interrogatory # 6 asks about agreements regarding music distribution rights and is directly relevant to Plaintiff's allegations that Defendants misled Plaintiff about their rights to music in order to induce Plaintiff to invest in Hits Only. E.g., DE 16 ¶¶ 15–16, 40 (allegations in the Amended Complaint). Again, confidentiality alone is not a basis to withhold discovery. Defendants' objections to Interrogatory
Accordingly, Plaintiff's Motion to Compel [DE 45] is GRANTED. Defendants must supplement their responses and answers as required under this Order within 14 days of the date of this Order.
DONE AND ORDERED in Chambers at Fort Lauderdale, Florida, this 23rd day of January, 2026.
PANAYOTTA AUGUSTIN-BIRCH UNITED STATES MAGISTRATE JUDGE
[fn 1]: Defendants failed to respond to the Motion to Compel in a timely manner and then, when they did respond, filed a response that violates the Court's three-page limitation for briefing on a discovery motion. See DE 42 at 3; DE 46; DE 47; DE 51. The parties are advised that failure to follow the Court's procedures in the future may lead to sanctions.