UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 22-CV-61997-AHS

GREAT AMERICAN INSURANCE COMPANY,

Plaintiff,

v.

ORACLE ELEVATOR HOLDCO, INC. and

EVEREST NATIONAL INSURANCE COMPANY,

Defendants.

________________________________________/

ORACLE ELEVATOR HOLDCO, INC. F/K/A OEC

HOLDING CORPORATION,

Third-Party Plaintiff,

v.

EVEREST NATIONAL INSURANCE COMPANY,

Third-Party Defendant.

________________________________

ORDER SETTING TELEPHONIC HEARING ON DISCOVERY MOTIONS

THIS CAUSE is before the Court upon: (i) Plaintiff Great American Insurance Company’s 

(“Great American”) Motion to Compel Production of Documents and Answers to Interrogatories 

from Defendant Everest National Insurance Company (“Everest”) (ECF No. 94); (ii) 

Defendant/Cross-Plaintiff Oracle Elevator Holdco, Inc.’s (“Oracle”) Motion to Compel Responses 

to Oracle’s First Set of Requests for Production and First Set of Interrogatories against Everest1

(ECF No. 100); and (iii) Oracle’s Motion to Compel Responses to Oracle’s First Set of Requests 

for Production and First Set of Interrogatories against Great American (ECF No. 101) (together,

1 Oracle previously filed a Notice of Joinder (ECF No. 96) in Great American’s motion to compel

(ECF No. 94), before separately filing its own motion to compel against Everest. See (ECF No. 

100).

Case 0:22-cv-61997-AHS Document 102 Entered on FLSD Docket 01/26/2024 Page 1 of 4
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the “Motions”). Based on the Court’s discovery procedures, responses to Oracle’s two motions to 

compel are due Monday, January 29, 2024. See http://www.flsd.uscourts.gov/content/judgealicia-o-valle (outlining Judge Valle’s expedited briefing schedule for discovery matters). No 

replies will be permitted. 

United States District Judge Raag Singhal has referred this case to the undersigned for all 

discovery matters. See (ECF No. 80). Accordingly, a telephonic hearing on the Motions is 

scheduled for Thursday, February 8, 2024, at 2 p.m. in the Fort Lauderdale Division before 

United States Magistrate Judge Alicia O. Valle. Shortly before the hearing time, the parties shall 

call (646) 828-7666 and, when prompted, enter Meeting ID 161 067 8281, followed by passcode 

1234. The Court has reserved two hours for the hearing.

Discovery Procedures: The Federal Rules of Civil Procedure “allow for broad discovery, 

which does not need to be admissible at trial,” Guzman v. Irmadan, Inc., 249 F.R.D. 399, 401 (S.D. 

Fla. 2008), and “strongly favor full discovery whenever possible,” Farnsworth v. Procter & 

Gamble Co., 758 F.2d 1545, 1547 (11th Cir. 1985). See Fed. R. Civ. P. 26(b)(1). Additionally, 

the Court does not recognize generalized boilerplate objections. See, e.g., Adelman v. Boy Scouts 

of Am., 276 F.R.D. 681, 688 (S.D. Fla. 2011) (“[J]udges in this District typically condemn 

boilerplate objections as legally inadequate or ‘meaningless.’”); Benfatto v. Wachovia Bank, N.A., 

No. 08-CV-60646, 2008 WL 4938418, at *2 (S.D. Fla. Nov. 19, 2008) (“[G]eneralized objections, 

which purport to object to each and every category of documents, are not recognized by this 

Court.”). Boilerplate objections may also border on a frivolous response to discovery requests. 

Steed v. Everhome Mortg. Co., 308 F. App’x 364, 371 (11th Cir. 2009). 

To the extent that a responding party withholds requested documents or information 

claiming protection by the attorney-client or other privilege, the responding party must serve the 

requesting party with a privilege log. See Fed. R. Civ. P. 26(b)(5)(A); see also NIACCF, Inc. v. 

Cold Stone Creamery, Inc., No. 12-CV-20756, 2014 WL 4545918, at *5 n.6 (S.D. Fla. Sept. 12, 

Case 0:22-cv-61997-AHS Document 102 Entered on FLSD Docket 01/26/2024 Page 2 of 4
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2014) (citing In re Denture Cream Prods. Liab. Litig., No. 09-2051-MD, 2012 WL 5057844, at 

*9 (S.D. Fla. Oct. 18, 2012)) (discussing the requirements of a privilege log). Lastly, the Court 

enforces Rule 37 regarding the assessment of fees in relation to discovery motions. See Fed. R. 

Civ. P. 37(a)(5). 

Joint Status Report: In advance of the hearing, the parties shall telephonically meet and 

confer in a good faith effort to resolve the issues in the Motions. By Monday, February 5, 2024, 

the parties shall file a Joint Status Report (“JSR”) on each of the Motions. The JSRs must set 

forth the following information for the unresolved issues, including without limitation: (i) the 

verbatim discovery request; (ii) the verbatim discovery response; (iii) a brief summary of each 

party’s position, with one issue per page; and (iv) the result of the parties’ meet and confer. The 

JSRs are not intended to be a verbatim recitation of the parties’ briefs. Rather, they are meant to 

summarize the issues in a comparative format (i.e., one column for movant and one column for 

opponent) to assist the Court in evaluating the disputed issues. This information must be presented 

in chart form as set forth in Exhibit 1. Moreover, if necessary, the parties may group the discovery 

requests by issue, as appropriate. The parties shall file and separately e-mail the Joint Status 

Reports, in Word format, to valle@flsd.uscourts.gov. 

DONE AND ORDERED in Chambers, at Fort Lauderdale, Florida, on January 26, 2024.

____________________________________

ALICIA O. VALLE

UNITED STATES MAGISTRATE JUDGE

cc: U.S. District Judge Raag Singhal

 All counsel of record

Case 0:22-cv-61997-AHS Document 102 Entered on FLSD Docket 01/26/2024 Page 3 of 4
EXHIBIT 1

JOINT STATUS REPORT

Request No. [ ]: [VERBATIM REQUEST]

Response: [VERBATIM RESPONSE]

Movant’s Position: Opponent’s Position: [LEAVE BLANK FOR COURT USE]

Request No. [ ]: [VERBATIM REQUEST]

Response: [VERBATIM RESPONSE]

Movant’s Position: Opponent’s Position: [LEAVE BLANK FOR COURT USE]

Request No. [ ]: [VERBATIM REQUEST]

Response: [VERBATIM RESPONSE]

Movant’s Position: Opponent’s Position [LEAVE BLANK FOR COURT USE]

Case 0:22-cv-61997-AHS Document 102 Entered on FLSD Docket 01/26/2024 Page 4 of 4