Pingree v. University of Utah, 2:20-cv-00724

Plaintiff Rita Florian Pingree filed motions to compel responses to her Fourth and Fifth sets of discovery requests against Defendants (Caroline Milne and University of Utah) in an employment dispute.
The Scheduling Order limited each party to 25 interrogatories and 35 requests for production, with discovery closing on September 2, 2023.
Plaintiff served the disputed discovery requests on August 3, 2023; Defendants responded after the deadline, initially without raising timeliness objections.
Defendants later asserted the requests were untimely and exceeded the allotted number of interrogatories and document requests.
After supplemental responses and meet-and-confers, Plaintiff filed the Motion to Compel three months after the discovery deadline.
The magistrate judge reviewed the timeliness, scope, and completeness of discovery responses, and denied the motion to compel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of Discovery Requests	Requests were timely as they allowed 30 days for response before busy schedules and counsel changes delayed filing motion.	Objections to timeliness raised after initial responses; claimed responses due after discovery period.	Defendants' timeliness objection waived as raised late; requests deemed timely.
Exceeding Allotted Discovery Requests	Plaintiff claims requests at issue were within the discovery limits.	Defendants assert some requests (esp. interrogatories) disguised multiple sub-parts, exceeding limits.	Court found some requests did exceed numerical limits, especially via subparts; objections upheld.
Sufficiency of Discovery Responses	Plaintiff claims responses were evasive, incomplete, or not sufficiently specific (e.g., document production, job duties).	Defendants state they produced voluminous documents using agreed search terms, supplemented responses, and objections were proper.	Court determined Defendants complied with obligations as per agreement and rules; no further action required.
Timeliness of Motion to Compel	Delay explained by counsel's workload, patience during counsel changes, and ongoing litigation.	Defendants note Plaintiff waited months after objections and last supplement, delaying case.	Court held the motion was untimely due to Plaintiff's delayed action.

Smith v. MCI Telecomm. Corp., 137 F.R.D. 25 (D. Kan. 1991) (broad construction of relevancy in discovery)
Centennial Archaeology, Inc. v. AECOM, Inc., 688 F.3d 673 (10th Cir. 2012) (courts have broad discretion over timeliness of motions to compel)
Buttler v. Benson, 193 F.R.D. 664 (D. Colo. 2000) (waiver of discovery remedies due to delay)