(d) A party to whom a discovery request is directed may object in writing for any of the following reasons:
- (1) Compliance with the request is unduly burdensome or expensive.
- (2) Compliance with the request will unduly delay the proceedings.
- (3) The request seeks information that is wholly outside of any matter in dispute.
- (4) The request seeks privileged information. Any party asserting a claim of privilege must sufficiently describe the information or document being withheld to show that the privilege applies. If an asserted privilege applies to only part of a document, a party withholding the entire document must state why the nonprivileged part is not segregable.
- (5) The disclosure of information responsive to the discovery request is prohibited by law.