RULING AND ORDER ON PLAINTIFF'S MOTION TO COMPEL DISCOVERY

ERIN WILDER-DOOMES, Magistrate Judge.

Before the Court is a Motion to Compel Discovery,1 filed by plaintiff Andrea Armstrong, as Executrix of the Estate of Glenn Ford under Rule 30 of the Federal Rules of Civil Procedure ("Plaintiff").2 The Motion is opposed.3 The Court finds that oral argument is not necessary.4 For the reasons that follow, the Motion is GRANTED in part.5

I. Background

On March 9, 2015, Glenn Ford filed a Complaint in this Court against Warden Burl Cain, Warden Ross Maggio, Warden John Whitley, Warden Peabody, Warden Robert Hilton Butler, Warden Frank C. Blackburn, Warden Darrel Vannoy, Prison Official Does 1-10, Dr. Cassidy, Dr. Macmurdo, Dr. Collins, Dr. Demars, Dr. Sparks, Doe Doctors 1-10, and ABC Insurance Companies 1-10 (collectively "Defendants"),6 alleging Defendants violated his rights during his nearly 30 years of wrongful imprisonment7 by maintaining unconstitutional living conditions and by being deliberately indifferent to his objective medical needs.8

Plaintiff asserts that she propounded her first set of Interrogatories and Requests for Production on June 16, 2016.9 After granting Defendants' request for a 30-day extension, Plaintiff claims Defendants provided discovery responses from August 18, 2016 to September 2, 2016.10 On September 27, 2016, Defendants supplemented some of their discovery responses, but Plaintiff asserts that Defendants objected to answering discovery requests that sought the following: (1) information and documents regarding any prior complaint made against each named defendant related to his duties at the Louisiana State Penitentiary at Angola ("Angola"); (2) information and documents regarding prior complaints by other Angola inmates alleging inadequate medical care and complaints by Angola inmates that are similar in nature to the allegations in Plaintiff's Complaint; (3) identification of the policymakers "for purposes of investigating the official policy for ensuring medical care for prisoners at Angola;" and (4) "any document that supports that any Defendant acted inconsistently with any policy at Angola."11 Plaintiff asserts that these categories of discovery are relevant to her claims of deliberate indifference and are narrowly tailored in subject matter and time, as the requests are limited to the thirty years that Glenn Ford was wrongfully imprisoned at Angola. Plaintiff claims that the parties met and conferred on October 19, 2016 in an attempt to resolve the dispute, but that they were unable to do so.

In the Opposition, Defendants assert that the discovery requests at issue are overly broad, burdensome, and not proportional to the needs of the case.12 Defendants claim that the requests for all prior complaints filed against all of the defendants are overly broad because they fail to specify a time period for the information and documents requested and because complaints made by inmates other than Glenn Ford are not related to the claims in this case. Defendants further assert that such discovery requests are overly burdensome, not proportional to the needs of the case, that the burden or expense of the proposed discovery outweighs its likely benefit, and that the documents requested are not reasonably accessible because of undue burden or cost.13 Defendants point out that ARPs were not scanned into the system at Angola until 2002, and that they typically range from 4-100 pages each.14 Once the ARPs are pulled, Defendants assert that a staff member would need to review each grievance to determine if any of the Defendants were named in the ARP, which is unduly burdensome. Defendants also assert that ARPs of other inmates are confidential and not subject to public inspection under Louisiana law.15 Thus, if the Court compels the production of ARPs filed by other inmates, Defendants contend that the Court must conduct an in camera review of the documents to determine whether the information should be turned over to Plaintiff.16

Defendants further assert that during the Rule 37 conference, Plaintiff's counsel indicated that Plaintiff's request to identify policymakers at Angola had been resolved.17 Nonetheless, Defendants assert that the request is vague and calls for a legal conclusion. Defendants also contend that Plaintiff's request for documents that "support a claim that any of the Individual Defendants acted inconsistently with any of the policies and practices of the [Louisiana Department of Corrections], and/or policies and practices in place at Angola" is overly broad, not tailored to this case, and not contemplated by the Federal Rules of Civil Procedure.18

II. Law and Analysis

Under Rule 26 of the Federal Rules of Civil Procedure, parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Fed. R. Civ. P. 26(b)(1). "For purposes of discovery, relevancy is construed broadly to encompass `any matter that bears on, or that reasonably could lead to other matters that could bear on, any issue related to the claim or defense of any party.'" Fraiche v. Sonitrol of Baton Rouge, 2010 WL 4809328, at *1 (M.D. La. Nov. 19, 2010) (quoting Coughlin v. Lee, 946 F.2d 1152, 1159 (5th Cir. 1991); Fed. R. Civ. P. 26(b)(1)).

However, the Court must limit discovery if it determines that:

Fed. R. Civ. P. 26(b)(2)(C). Motions to compel discovery responses are governed by Rule 37(a) of the Federal Rules of Civil Procedure. "Rule 37(a)(3)(B) provides that a party seeking discovery may move for an order compelling production or answers against another party when the latter has failed to produce documents requested under Federal Rule of Civil Procedure 34 or to answer interrogatories under Federal Rule of Civil Procedure 33." Gondola v. USMD PPM, LLC, 2016 WL 3031852, at *2 (N.D. Tex. May 27, 2016) (citing Fed. R. Civ. P. 37(a)(3)(B)(iii)-(iv)). "The party resisting discovery must show specifically how each discovery request is not relevant or otherwise objectionable." Gondola, 2016 WL 3031852 at *2 (citing McLeod, Alexander, Powel & Apffel, P.C. v. Quarles, 894 F.2d 1482, 1485 (5th Cir. 1990)).

A. Discovery Regarding Prior Complaints Against the Named Defendants.

In the Motion to Compel, Plaintiff seeks to compel Defendants to respond to the following discovery requests regarding any prior complaints made against the named defendants:

Defendants objected to these requests, asserting that any requests for prior complaints and ARPs made by inmates other than Glenn Ford are overly broad and not related to Plaintiff's allegations. Defendants also assert that the discovery requests are unduly burdensome, not proportional to the needs of the case, that the burden or expense of the proposed discovery outweighs its likely benefit, and that these documents are not reasonably accessible because of undue burden or cost.20

The Court agrees that Plaintiff's requests are overbroad and unduly burdensome to the extent that they seek information and documents regarding any prior complaint made against the named defendants. A request for all prior complaints or lawsuits filed against the named defendants alleging "that you or your office provided inadequate medical evaluation or care, inadequate access to medical evaluation or care, or violated the Constitution of the United States in discharging your or your office's responsibilities" or "alleging any kind of misconduct committed by any Individual Defendant" encompasses a large array of possible information, not all of which is reasonably calculated to lead to the discovery of admissible evidence. Parties are not required to produce discovery if it would be unduly burdensome. Fed. R. Civ. P. 26(b)(2)(C). Plaintiff has not demonstrated that these discovery requests are reasonably calculated to lead to the discovery of admissible evidence.

Although evidence of other bad acts committed by a defendant is not generally admissible to prove the character of that person or to show that he acted in conformity with such bad character on a particular occasion, Rule 404 of the Federal Rules of Evidence provides that such evidence may be admissible for other purposes, as for example, to show intent or knowledge. F.R.E. Rule 404(b). In United States v. Beechum, 582 F.2d 898 (5th Cir. 1978) (en banc), the Fifth Circuit construed Rule 404(b) in the light of the other Rules of Evidence and concluded that this Rule mandates a two-step analysis: "First, it must be determined that the extrinsic evidence offense is relevant to an issue other than the defendant's character. Second, the evidence must possess probative value that is not substantially outweighed by its undue prejudice and must meet the other requirements of Rule 403." Id. Further, the Beechum court defined how extrinsic offenses may be relevant to the proof of intent in connection with another unrelated action, to wit:

Id. Where extrinsic evidence of other offenses is sought to be introduced, its relevance is a function of its similarity to the offense charged and, for purposes of determining relevancy, "a fact is similar to another only when the common characteristic is the significant one for the purposes of the inquiry at hand." Id. (quoting Stone, The Rule of Exclusion of Similar Fact Evidence: England, 46 Harv.L.Rev. 954 (1933)).

Applying the foregoing standard, the Court finds that some of the information and documents that Plaintiff seeks are potentially relevant. However, the Court finds it appropriate to limit Plaintiff's discovery requests to prior complaints or lawsuits filed against the named defendants that allege claims only of deliberate medical indifference with respect to failure to adequately treat cancer. Further, the information and documentation provided shall be limited to complaints and lawsuits filed within a five-year period preceding the filing of this suit. For any prior complaint produced in accordance with this Order, Defendants shall redact the name and any identifying information of the Angola inmate who submitted the grievance in order to protect the privacy interests of third parties.21 Subject to the foregoing limitations, the Court will direct Defendants to provide supplemental responses to Interrogatory No.3, Request for Production No. 22, and Request for Production No. 33. The Court further finds that Plaintiff is not foreclosed from seeking additional documents, if necessary, after reviewing the supplemental responses provided pursuant to this Order. Upon seeking such relief, however, Plaintiff must articulate a particular need for any additional documents requested.

B. Discovery Regarding Any Prior Complaints Filed by Angola Inmates Alleging Inadequate Medical Treatment.

Plaintiff also seeks to compel Defendants to respond to the following requests for documents pertaining to any prior complaints made by Angola inmates regarding inadequate medical treatment and improper living conditions:

Defendants objected to the foregoing requests asserting that the requests are overly broad, unduly burdensome, not proportional to the needs of the case, that the burden or expense of the proposed discovery outweighs its likely benefits, and that the documents are not reasonably accessible because of undue burden or cost.23 The Court agrees that these requests are overly broad, unduly burdensome, irrelevant, and not reasonably calculated to lead to the discovery of admissible evidence. With regard to Requests for Production Nos. 24, 25 and 26, Plaintiff has not shown how grievances filed by other inmates at Angola alleging inadequate medical care or denial of medical care are relevant to Plaintiff's allegations that these specific Defendants failed to adequately treat Glenn Ford's lung cancer. The Court has already permitted discovery of such allegations against the named defendants as set forth in Section II(A), supra. As such, the Court will not compel responses to Request for Production Nos. 24, 25, and 26.

With respect to Request for Production No. 40, the Court finds that while the request for "All documents that relate to any Complaint" related to the specific categories listed is overly broad, some of the documents that Plaintiff seeks are potentially relevant to her claims that Glenn Ford was subjected to unconstitutional living conditions. As such, the Court will limit Plaintiff's Request for Production No. 40 to prior complaints involving any named defendant filed within a five-year period preceding the filing of this lawsuit that relate to the seven categories specifically listed. However, for each grievance that is produced in accordance with this Order, Defendants shall redact the name and any other identifying information of the Angola inmate who filed the complaint in order to protect the privacy interests of third parties. Subject to the foregoing limitations, the Court will direct Defendants to provide a supplemental response to Request for Production No. 40. The Court further finds that Plaintiff is not foreclosed from seeking additional documents, if necessary, after reviewing the supplemental response provided pursuant to this Order. Upon seeking such relief, however, Plaintiff must articulate a particular need any additional documents requested.

C. Discovery Regarding Policymakers and Angola's Medical Policy

The third category of information and documents that Plaintiff seeks to compel from Defendants concerns the policy at Angola regarding inmate medical care. Specifically, Plaintiff seeks to compel Defendants to respond to the following requests for information and documents:

Defendants object to these requests, asserting that during the Rule 37 conference, counsel for Plaintiff indicated that the dispute regarding Interrogatory No. 12 had been resolved.25 Defendants claim that Plaintiff does not indicate how or why the responses are deficient and further assert that the requests are vague, overly broad, and call for a legal conclusion. The Court agrees that these requests are overly broad and vague. However, the Court finds that some of the information that Plaintiff seeks is potentially relevant. With respect to Interrogatory No. 12, the Court will limit Plaintiff's request to identifying the policymaker or policymakers at Angola who were responsible for ensuring that inmates at Angola received adequate medical treatment during Glenn Ford's incarceration from 1984 through his release on March 10, 2014.26 With respect to Request for Production No. 21 the Court finds the request to be vague and duplicative of Request for Production Nos. 22, 24-26, 33, and 40, previously addressed in this Order. Thus, the Court will not compel a response to Request for Production No. 21.

III. Conclusion

For the reasons set forth herein, Plaintiff's Motion to Compel Discovery27 is GRANTED in part, such that, within twenty-one (21) days of the date of this Order, Defendants shall supplement their responses to Plaintiff's discovery requests by filing into the record of this proceeding:

IT IS FURTHER ORDERED that Plaintiff's Motion to Compel28 is OTHERWISE DENIED.

IT IS FURTHER ORDERED that Plaintiff shall seek additional authorization from this Court prior to seeking to compel additional documents from Defendants. Any request for additional documents beyond those authorized by this Order shall be accompanied by specific facts that articulate the need for the additional documentation.

As the Court finds that oral argument on the Motion to Compel Discovery is not necessary29 and the Court has already determined that oral argument is no longer necessary on Plaintiff's Motion for Leave to Take More Than 10 Depositions,30 IT IS FURTHER ORDERED that the Motion Hearing set for December 28, 2016 at 9:30 a.m. in Courtroom 5 before the undersigned Magistrate Judge is CANCELLED.