In Fischer v. Forrest, 14 Civ. 1304 (PAE) (AJP), 14 Civ. 1307 (PAE) (AJP) (S.D.N.Y. Feb. 28, 2017), Magistrate Judge Andrew J. Peck issued a strongly-worded decision criticizing a party’s “form” objections to requests to produce documents, including electronically stored information.  First, Judge Peck disapproved of the use of general objections because they fail to state objections with specificity, as required under Rule 34(b)(2)(B), or to indicate whether any responsive materials were being withheld on the basis of the objections, as required under Rule 34(b)(2)(C).  Judge Peck opined:  “General objections should rarely be used after December 1, 2015[.]”  Second, Judge Peck held that objections made “to the extent [requests] call for the disclosure of information that is not . . . likely to lead to the discovery of relevant, admissible evidence” no longer conform to Rule 26(b)(1).  Rule 26(b)(1) was amended December 1, 2015, to limit discovery to material “relevant to any party’s claim or defense” and no longer includes information “likely to lead” to evidence.  Third, Judge Peck called objections that the requests were “overly broad and unduly burdensome”  “meaningless boilerplate.”  Fourth, Judge Peck disapproved of the responding party’s failure to indicate any timeline for its productions.  Judge Peck ordered the responding party to revise its responses.  In conclusion, Judge Peck ordered: “From now on in cases before this Court, any discovery response that does not comply with Rule 34’s requirement to state objections with specificity (and to clearly indicate whether responsive material is being withheld on the basis of objection) will be deemed a waiver of all objections (except as to privilege)” (emphasis added).