Florida Circuit Court (State)
Question regarding Motions to Compel and evasive or incomplete discovery.
I filed a first request for productions, admission and interrogatories and the Plaintiff responded with Objections claiming
My request for first production of doc's
1) "overly broad, unduly burdensome and not reasonably calculated to the discovery of admissible information"
2) Objections to relevance. Without waiving said object, denied as stated.

I know I gave them allot work to provide but this is what they (attorneys) due to a defendant or a plaintiff. All of the requests for admissions, documents and interrogatories were tailored for my case from typical pleadings. I found most of the questions for interrogatories from typical bankruptcy and credit card debt cases.

Question... How should I word a request for production in a Motion to Compel as to not piss off the Judge. I am on my own and have some legal experience but not seasoned. The plaintiff failed to provide the original documents, admit or deny, and failed to provide a complete first request for interogatories.

Also, I don't have access to lexis or westlaw anymore and like a case citation or two for my memorandum in support of discovery complaince.