John BAL, in the capacity as a Democratic candidate for the New York state assembly, Plaintiff, v. MANHATTAN DEMOCRATIC PARTY, Ketih Wright, personally and in the capacity of County Leader, New York County Democratic Committee, and Cathleen McCadden, personally and in the capacity of executive director, Defendant 16cv02416 (PKC) (DF) United States District Court, S.D. New York Signed March 14, 2018 Counsel John Bal, New York, NY, Pro Se. Gregory Charles Soumas, Bedford Soumas LLP, New York, NY, Arthur Z. Schwartz, Advocates for Justice, Chartered Attorneys, New York, NY, for Defendants Manhattan Democratic Party, Keith Wright, New York County Democratic Committee, Cathleen McCadden. Freeman, Debra, United States Magistrate Judge ORDER *1 Currently before this Court, to which the above-captioned case has been referred for general pretrial supervision, are two extensive discovery motions. In the first of the filed motions (Dkt. 65), defendants Manhattan Democratic Party (“MDP”), Keith Wright (“Wright”) (sued personally and in his capacity as County Leader), the New York County Democratic Committee (“NYCDC”),[1] and Cathleen McCadden (“McCadden”) (sued personally and in her capacity as Executive Director) (collectively, “Defendants”) seek to compel plaintiff John Bal (“Plaintiff”) to respond more fully to interrogatories and to produce documents called for by those interrogatories.[2] In the second filed motion (Dkt. 66), Plaintiff, proceeding pro se, seeks to compel Defendants to respond fully to requests for admissions and the individual Defendants, Wright and McCadden, to provide further responses to certain interrogatories and document requests. In addition, in a third pending motion (Dkt. 72), Dora P. Georgescu Esq. (“Georgescu”), who has appeared for Plaintiff in this action for the limited purpose of representing him, pro bono, in connection with depositions, seeks an extension of the discovery deadline until a date 30 days after this Court's ruling on the two referenced motions to compel. For the reasons discussed below, (1) both motions to compel are granted in part and denied in part; (2) no party to this action may serve any additional interrogatories or document requests absent stipulation or leave of Court; and (3) the motion for a discovery extension is granted, with depositions to be completed within 30 days of the parties’ supplementation of their discovery responses, consistent with this Order. BACKGROUND A. Factual Backgound As a result of the November 30, 2015 conviction of then-New York State Assembly Member Sheldon Silver (“Silver”) on federal corruption charges,[3] Silver's Assembly seat became vacant. (See Complaint, dated Mar 29, 2016 (“Compl.”) (Dkt. 2) ¶ 3.) In order to fill the vacancy, New York Governor Andrew Cuomo ordered that a special election be held, in the 65th Assembly District (“65th AD”), on April 19, 2016 (the “Special Election”). (Id. ¶ 4.) Plaintiff sought to become the Democratic Party candidate for the Special Election, but claims in this case that the MDP's nomination process to select its candidate was “undemocratic” and “undermined his candidacy.” (Id. ¶ 2.) More specifically, Plaintiff alleges that, through various “improprieties,” including withholding information from him regarding the nominating process, unreasonably delaying the provision to him of a list of County Committee Members (“CCMs”), and failing to follow the MDP's own Rules and Regulations (the “Party Rules”) (id. ¶ 8), Defendants denied him his “right to meaningfully compete for the Democratic nomination,” in violation of the First and 14th Amendments (id. ¶ 9). B. Relevant Procedural History *2 Shortly after this case was referred to this Court by the Honorable P. Kevin Castel, U.S.D.J., for general pretrial supervision (Dkt. 11), this Court stayed discovery, in light of a motion to dismiss that was filed on behalf of then-defendant New York State Board of Elections. (See Dkts. 25, 26.) When Plaintiff voluntarily dismissed that defendant from the action (see Dkt. 43), this Court lifted the stay, setting April 14, 2017 as the deadline for the completion of all fact discovery (Dkt. 45). Since this Court set that schedule, its management of discovery in this action has been challenging, made more difficult by the parties’ seeming unwillingness or inability to cooperate or to follow this Court's instructions. On December 21, 2016, this Court held a case management conference, at which Plaintiff stated that, although he would remain reachable by email, he would be out of the country, for medical treatment, from mid-January until late April, 2017. (See Dkt. 51.) As a result of Plaintiff's planned absence, this Court extended the close of discovery to May 12, 2017. (Id.) This Court also directed the parties to submit a joint letter by February 24, 2017, regarding the status of discovery. (Id.) Instead of submitting a joint letter, however, the parties each submitted separate letters (Dkts. 54, 56), the content of which suggested to this Court that they had not been conferring in good faith regarding discovery disputes. In a March 1, 2017 Order, this Court wrote: At this point, it is not clear to this Court whether the parties have any remaining discovery disputes. If they do, and they are unable to resolve them through full, good-faith conference, then they may bring those disputes to this Court's attention. In any event, the parties are directed to submit a joint update on the status of discovery no later than April 14, 2017. (Dkt. 60 (emphasis in original).) Once again, however, instead of submitting a joint letter, the parties submitted separate letters, each accusing the other side of a failure to cooperate. (See Dkts. 61 (Defendants’ counsel stating “Plaintiff seems intent on engaging in ad hominem attacks against me and he is not cooperating with Defendants’ discovery”), 62 (Plaintiff stating that the conduct of Defendants’ counsel “demonstrates a lack of good-faith participation in the discovery process”).) Having received these letters, this Court held another case management conference on April 27, 2017, at which it urged the parties to confer meaningfully regarding their disputes, and to make efforts to narrow the number and scope of their discovery demands. (See Dkt. 64.) In a written Order dated May 1, 2017, this Court memorialized its rulings at the conference, stating, in relevant part: If, after good-faith conference, Plaintiff and the County Defendants are unable to resolve their discovery disputes, then, no later than May 19, 2017, either party seeking to compel the further production of documents or information is directed to file a motion to compel such discovery. Any such motion should set forth, with specificity, (a) the discovery request(s) at issue, (b) the opposing party's response(s), (c) the extent to which the dispute has been narrowed, if at all, through the parties’ efforts at good-faith conference, and (d) how the requested discovery is relevant to any claim or defense asserted in this action. Papers in opposition to any such motion shall be filed no later than June 2, 2017, and replies, if any, shall be filed no later than 6:00 p.m. on June 6, 2017. (Id.) Further, “in light of Plaintiff's pro se status, the seeming extent of the parties’ discovery disputes regarding the adequacy of responses to document requests and interrogatories, and the fact that the parties wish[ed] to resolve those disputes prior to proceeding with depositions,” this Court granted another extension of the fact-discovery period, to July 31, 2017. (Id.) This Court noted that no further extensions of that deadline would be granted, “absent a showing of extraordinary cause.” (Id.) C. The Pending Discovery Motions *3 On May 19, 2017, both Plaintiff and Defendants filed motions to compel. (See Letter to the Court from Gregory C. Soumas, Esq. (“Soumas”), dated May 19, 2017 (“Def. Mtn.”) (Dkt. 65); Plaintiff's Motion To Compel Discovery, dated May 19, 2017 (“Pl. Mtn.”) (Dkt. 66).) The parties filed timely oppositions to those motions (see Letter to the Court from Soumas, dated June 2, 2017 (“Def. Opp.”) (Dkt. 67); Plaintiff's Response to Defendants’ Letter To Compel Discovery, dated June 2, 2017 (“Pl. Opp.”) (Dkt. 68)[4]), and also timely filed replies (see Plaintiff's Reply to Defendants’ Opposition Letter To Compel Discovery, dated June 6, 2017 (“Pl. Reply”) (Dkt. 69); Letter to the Court from Soumas, dated June 6, 2017 (“Def. Reply”) (Dkt. 70)). Before addressing these motions below, this Court makes the following observations. First, most of the parties’ disputes center on the adequacy of responses to interrogatories, but the interrogatories served by both Plaintiff and Defendants in this case well exceed the scope of discovery permitted by the Federal Rules of Civil Procedure. In particular, absent stipulation or court order, Rule 33(a)(1) limits the number of interrogatories that may be served to 25, including subparts. Both Plaintiff and Defendants have so far exceeded this limit – by serving 75 and 94 interrogatories, respectively, both with so many subparts that a fair count for each is well into the hundreds – that their discovery demands can only be considered abusive. Second, many of the interrogatories served, by both Plaintiff and Defendants, violate Local Civil Rule 33.3(b), in that they call for lengthy narrative responses that plainly make them a less practical method of obtaining the discovery sought than a deposition. Third, many of the interrogatories served, by both Plaintiff and Defendants, either call for information that is plainly irrelevant to any claim or defense asserted in this action, or are improper for other reasons, discussed further below. Finally, this Court notes that, while Plaintiff is representing himself for purposes of propounding and responding to written discovery requests, such that his papers should be viewed with leniency, Defendants are represented by counsel, who can have no excuse for burdening Plaintiff and the Court with excessive, overbroad, and improper demands. It is also frustrating to this Court that Defendants’ counsel ignored its explicit instructions as to how any motion to compel should be presented to the Court. To reiterate, this Court instructed the parties that any such motion should: set forth, with specificity, (a) the discovery request(s) at issue, (b) the opposing party's response(s), (c) the extent to which the dispute has been narrowed, if at all, through the parties’ efforts at good-faith conference, and (d) how the requested discovery is relevant to any claim or defense asserted in this action. (Dkt. 64.) Defendants’ motion states, at the outset, that Plaintiff should be compelled “to respond to all of Defendants’ interrogatories and document requests.” (Def. Mtn., at 1 (emphasis added).) Defendants, however, neither quoted nor even provided copies of their discovery demands to the Court. Nor did they provide Plaintiff's responses. Rather, this Court has only located copies of Defendants’ demands and Plaintiff's responses in the materials submitted by Plaintiff. Certainly, Defendants made no attempt to parse through their requests item by item, to set forth Plaintiff's particular responses, to discuss the results of any good-faith conference with respect to the specific requests made, or to state, with specificity, how each request is relevant to the parties’ claims or defenses. Instead, in their motion, Defendants broadly listed 13 categories of information or documents that they claim to have requested (leaving this Court to guess at which of their interrogatories or document requests may fall within these categories), generally described how Plaintiff's responses were supposedly deficient, and provided minimal and often conclusory arguments regarding relevance. Given the sloppy manner in which counsel has presented Defendants’ motion to this Court, combined with Defendants’ failure to comply with both the Federal and Local Rules, this Court would be entirely justified in denying Defendants’ motion wholesale. *4 Nonetheless, discovery in this case needs to come to a conclusion, and this Court does not wish to be faced with unnecessary follow-up motions. Accordingly, this Court has endeavored to ascertain the key disputes being raised by Defendants and to address them below, together with the issues raised by Plaintiff's motion. At the end of its decision, this Court will set a schedule for the parties to supplement their discovery responses as required by this Court's Order. In addition, this Court will address the motion brought by Plaintiff's limited-appearance pro bono counsel for an extension of the discovery schedule, to allow for depositions to be conducted after this Court rules on the parties’ discovery disputes. (See Letter to the Court from Georgescu, dated July 17, 2017 (“Georgescu Mtn.”) (Dkt. 72).) DISCUSSION I. DEFENDANTS’ MOTION TO COMPEL (Dkt. 65) Defendants apparently served Plaintiff with four sets of discovery requests. In the first, Defendants propounded 39 interrogatories, many with numerous subparts. (Defendants’ First Set of Interrogatories and First Request for Production of Documents, dated Nov. 14, 2016 (“Def. First Requests”) (Dkt. 68, at 29-42[5]).) Seemingly unsatisfied with Plaintiff's responses, Defendants then proceeded to serve a second set of demands that included 30 interrogatories, some of which were identical to those that had already been served (see Defendants’ Second Set of Interrogatories and Second Request for Production of Documents, dated Mar. 30, 2017 (“Def. Second Requests”) (Dkt. 68-4, at 1-9)), a third set that included another six interrogatories (see Defendants’ Third Set of Interrogatories and Third Request for Production of Documents, dated Apr. 10, 2017 (“Def. Third Requests”) (Dkt. 68-4, at 15-20)), and a fourth set that included another 19 interrogatories (see Defendants’ Fourth Set of Interrogatories, dated Apr. 28, 2017 (“Def. Fourth Requests”) (Dkt. 68-4, at 24-27)). It appears that Plaintiff served responses, followed by amended responses, to the first set of Defendants’ demands (see Plaintiff's Response to Defendants’ First Set of Interrogatories and Production of Documents, dated Nov. 21, 2016 (Dkt. 68, at 44-49); Amended Plaintiff's Response to Defendants’ First Set of Interrogatories and Production of Documents, dated May 12, 2017 (“Pl. Am. Responses”) (Dkt. 68-2, at 33-41)), but did not respond to the rest. As noted above, Defendants, in their motion, make a blanket request to this Court to compel Plaintiff to respond to all of Defendants’ discovery demands. (Def. Mtn., at 1.) That request is denied. To the extent Defendants seek to compel Plaintiff to respond to particular categories of discovery requests, Defendants’ motion is resolved as follows: A. Defendants’ First Set of Discovery Requests With respect to their first set of discovery requests, Defendants list four categories of challenges to Plaintiff's responses: (1) Plaintiff's assertions of work product immunity as to certain requested documents; (2) Plaintiff's supposed refusal to provide a “witness list”; (3) Plaintiff's supposedly “scant and indecisive” response to Defendants’ requests regarding his membership in the MDP and the “manner” of his Party enrollment; and (4) Plaintiff's supposed failure to produce his “campaign finance records.” (Def. Mtn., at 2-3.) 1. Plaintiff's Assertion of “Work Product” This Court assumes that Defendants are here complaining about Plaintiff's responses to Defendants’ Interrogatories Nos. 6, 7, and 8, which appear to be the only requests as to which Plaintiff asserted a “work product” objection. (See Pl. Am. Responses, Dkt. 68-2, at 34.) Interrogatory No. 6 asks Plaintiff to state whether he has “obtained a statement from any person not a party to this action with respect to the subject matter of this action.” (Def. First Requests, Dkt. 68, at 35.) Interrogatory No. 7 asks that, if Plaintiff's answer to Interrogatory No. 6 is “yes,” he provide information regarding the identity of the person who gave the statement, when it was obtained, whether it was written and signed, or oral and otherwise recorded; the request further asks for production of copies or transcripts of any such statements, and for Plaintiff to “[s]et forth completely the substance and content of any oral or recorded statements.” (Id., at 35-36.) Interrogatory No. 8 (which largely appears to be boilerplate and not tailored to this single-plaintiff case) then asks whether Plaintiff has “obtained a statement from plaintiffs or any agents, servants, employees or employers of plaintiffs,” and, if “yes,” to provide specified information regarding any such statements. (See id., at 36.) *5 In his opposition to Defendants’ motion, Plaintiff states that he has asserted work-product protection “solely for the legal research done in anticipation of this litigation.” (Pl. Opp., at 5.) From this, it appears that Plaintiff may not have obtained any witness statements, despite his assertion of a work-product objection to the Interrogatories in question. In any event, if Plaintiff is claiming work-product protection with respect to any documents that would be responsive to any of Defendants’ discovery requests addressed herein, including but not limited to any witness statements, then he is instructed to provide Defendants with a privilege log that is compliant with Local Civil Rule 26.2. Such log need only list documents generated prior to the commencement of this litigation. 2. Defendants’ Request for Plaintiff's “Witness List” Based on the arguments contained in Defendants’ motion (Def. Mtn., at 2), this Court understands that Defendants’ complaint here relates to Plaintiff's response to Defendants’ Interrogatory No. 1(b), in which Defendants ask Plaintiff, with reference to each person identified by Plaintiff as “having knowledge of facts relevant to the subject matter of this action” (Def. First Requests, Dkt. 68, at 33), to “state in full detail the relevant knowledge possessed by him” (id., at 34). Plaintiff responded to this Interrogatory by stating that each of the witnesses he had identified “have relevant knowledge regarding Democratic club endorsements and the nominating process for 65th AD Assembly Member in the Special Election held April 19, 2016.” (Pl. Am. Responses, Dkt. 68-2, at 34.) According to Defendants, this “one sentence summary” lacks sufficient “detail or specificity.” (Def. Mtn., at 2.) An interrogatory calling for Plaintiff to “state in full detail” witnesses’ relevant knowledge is improper, both because Plaintiff cannot know the full extent of anyone's knowledge other than his own, and because it is not a more practical method of obtaining the information sought than depositions, see Local Civ. R. 33.3(b). Nonetheless, so as to assist Defendants in determining which of the 14 identified witnesses they may wish to depose, Defendants’ application to compel a supplemental response is granted to the limited extent that Plaintiff is directed to identify, separately as to each named witness, the subject matter of the discoverable information that each witness is likely to possess, differentiating among the witnesses’ likely knowledge to the extent possible. 3. Defendants’ Request for Plaintiff's “Association with the New York County Democratic Party Committee” With respect to this category, Defendants argue, in their motion, that “[f]undamental and prerequisite to the right to participate in the nominating process of the New York County Democratic Party Committee is maintaining valid membership in the Party,” and that “[m]embership in the Party is critical to the viability of Plaintiff's allegations and respectively relevant to Defendants[’] denial herein.” (Def. Mtn., at 2.) Despite this argument, nowhere in Defendants’ discovery demands do Defendants actually ask Plaintiff to confirm his membership “in the [Democratic] Party.” The closest Defendants come to this is in Interrogatory No. 33, by which they ask Plaintiff to “[s]tate whether and when [he was] a member” of the New York County Democratic Party County Committee. (Def. First Requests, Dkt. 68, at 41.) Presumably, based on this and on the heading in their motion (Def. Mtn., at 2), Defendants are challenging Plaintiff's response to that interrogatory, and they may also be challenging Plaintiff's response to Interrogatory Nos. 32 (which asks Plaintiff to “[d]escribe in detail the method and manner” for becoming a member of that Committee (id.)) and 34 (which asks Plaintiff to “[d]escribe the method and manner” in which he became a member of that Committee (id.)). *6 Plaintiff responded to these Interrogatories by stating the following: 32. Democratic clubs select a male and female candidate for [CCM] from each Election District [“ED”] in an Assembly District. These candidates are voted upon in the Primary Election. The winners become [CCMs]. 33. In the mid-1970's, I seem to remember being elected either a [CCM] or a State Committee Member. For interrogatory purposes, I will assume that I was elected [CCM]. 34. My name was placed in the electoral process for [CCM]. I was a successful candidate. I do not recall if there was any opposition to my candidacy. (Pl. Am. Responses, Dkt. 68-2, at 39-40.) Defendants have not demonstrated the relevance to Plaintiff's claims or to their defenses of Plaintiff's County Committee Membership, or lack thereof, as they have not shown that only CCMs were eligible to seek nomination for the Special Election for the State Assembly. Even assuming that this was true, this Court finds Plaintiff's responses to be sufficient, especially given that the method by which individuals were selected as CCMs should be known to Defendants, and Defendants should also have records as to the members, at the relevant time, of their own County Committee. Moreover, Plaintiff has stated in opposition to Defendants’ motion that he “has been a loyal life-long member of the Democratic Party” (Pl. Opp., at 6 (emphasis added)), which is what Defendants now claim that they need to know (even though it was not what they asked); he has attached as an exhibit to his opposition papers a copy of his Board of Elections record, purportedly demonstrating his active Party membership since January 1, 1971 (Dkt. 68-4, Ex. T); and he has stated that, since 1971, he “has continually been an enrolled member of the Democratic Party” (id.). For all these reasons, any application by Defendants for a further response to Interrogatories Nos. 32, 33, and 34 is denied. If Defendants believe that they need sworn testimony from Plaintiff regarding his Party membership, as specifically related to his eligibility for the Assembly seat he was seeking, then they may pose appropriate questions to him at his deposition. 4. Defendants’ Request for Plaintiff's “Campaign Finance Records” Defendants next argue that Plaintiff should be compelled to respond to a discovery request “regarding Plaintiff's campaign finance records.” (Def. Mtn., at 2.) According to Defendants, New York State election law requires candidates to register with the State Board of Elections “if they expect to make certain expenditures or receipts.” (Def. Mtn., at 2-3 (citing N.Y.S. Election Law § 14-102).) Defendants argue that their “request for any campaign finance records is directly relevant to the denial of the allegations herein and the lack thereof is further evidence of the frivolity of the instant matter.” (Id., at 3.) In reviewing Defendants’ first set of discovery requests, however, the closest this Court sees to a request regarding “campaign finance records” is Defendants’ Interrogatory No. 36, which asks Plaintiff to “[s]tate in detail the amount of funds raised and expended by your campaign.” (Def. First Requests, Dkt. 68, at 41.) Plaintiff responded to this Interrogatory by stating that “[n]o funds were raised,” and that he had “[m]inimal out-of-pocket expenses.” (Pl. Am. Responses, Dkt. 68-2, at 40.) *7 Defendants have failed to show the relevance of their request to the claims or defenses asserted in this action, or why they would need a “detailed” accounting of Plaintiff's campaign expenses. Under these circumstances, Defendants’ application to compel a further response to this Interrogatory is denied. B. Defendants’ Second Set of Discovery Requests In his opposition to Defendants’ motion, Plaintiff states that, even though he responded to all of interrogatories contained in Defendants’ first discovery request, he did not respond to Defendants’ subsequently served interrogatories (either in Defendants’ second, third, or forth sets of discovery requests), based on Defendant's violation of Rule 33(a)(1) of the Federal Rules of Civil Procedure, which imposes a limit on the number of interrogatories that are permissible. (Pl. Opp., at 4-5.) As noted above, though, while he was obviously familiar with the limitation imposed by Rule 33(a)(1), Plaintiff himself served well in excess of 25 interrogatories on Defendants. Thus, while Plaintiff's objection to Defendants’ excessive number of interrogatories may have been valid, his assertion of it here is an example of the pot calling the kettle black. This Court will therefore consider the remainder of Defendants’ arguments as to why Plaintiff should respond to certain additional categories of interrogatories, starting with those contained in Defendants’ second set of discovery requests. With respect to their second set of discovery requests, Defendants list two categories of information and documents that they claim to need from Plaintiff: (1) information regarding Plaintiff's attendance (or lack thereof) at a nominating convention, and (2) information regarding Plaintiff's primary residence, realty owned, and voting record, and copies of Plaintiff's tax returns. (Def. Mem., at 3.) 1. Defendants’ Request for Plaintiff's “Attendance at Nominating Convention held February 7, 2016” This category identified in Defendants’ motion (see Def. Mtn., at 3) presumably relates to Interrogatory No. 11, as propounded in Defendants’ second set of discovery requests. That Interrogatory asks Plaintiff to state whether he “attended the convention to nominate and elect a Democratic Party candidate for the 65th Assembly District as alleged in paragraph 28 of the Complaint.” (Def. Second Requests, Dkt. 68-4, at 7.) This Court notes, however, that paragraph 28 of the Complaint alleges, in its entirety, that “Defendant Wright, Leader of the MDP, by his actions and omissions, negligently conducted an unconstitutional nominating process” (Compl. ¶ 28), and thus contains no specific reference to any nominating convention. Moreover, despite the fact that not a single interrogatory contained in Defendants’ second set of requests references the date of any nominating convention, Defendants now argue in their motion that this Court should compel Plaintiff to respond to “Defendants’ request as to whether Plaintiff attended the nominating convention on February 7, 2016,” suggesting that a response to this request (which does not even track the Interrogatory actually propounded) would be “probative of [Plaintiff's] unavailability for election.” (Def. Mtn., at 3.) Defendants have not shown that their Interrogatory No. 11 is even capable of being responded to as framed, given its reference to a paragraph of the Complaint that does not mention a nominating convention. Further, Defendants’ argument regarding the relevance of their inquiry, as recast in their motion, is unconvincing. Plaintiff alleges in the Complaint that he withdrew his candidacy on February 3, 2016. (Compl. ¶ 2.) Accordingly, if Defendants violated any of Plaintiff's rights, any such violation would necessarily have occurred prior to that date, and, even assuming that a nominating convention was then held on February 7, 2016, Plaintiff's attendance or lack of attendance at that convention would bear no relevance to his claims. Defendants’ application to compel a response to this Interrogatory is therefore denied. 2. Defendants’ Request for Plaintiff's “Primary Residence, Tax Returns, Realty Owned and Voting Record” *8 Defendants argue in their motion that “Plaintiff must establish a qualifying primary residence to sustain the underlying argument of membership to [sic] the Party and entitlement to participation in the nominating process.” (Def. Mtn., at 3.) Defendants further argue that “Plaintiff's tax returns are the most verifiable source for his primary residence and completely within his possession.” (Id.) Presumably, Defendants are seeking responses to Interrogatories Nos. 23 (which asks Plaintiff to state his “address of primary residence” (Def. Second Requests, Dkt. 68-4, at 8)), 24 (which asks him to “[p]rovide [his] federal, state, and local income tax returns for the last ten year period” (id.)), 25 (which asks him to state the address where he is “register [sic] to vote” (id., at 9)), 26 (which asks him to state whether he has “voted in any party primary election or general election or special election other than from [his] primary residence in the last ten year period” (id.)), 27 (which asks him to state the “address of all residential real estate owned by [him] during the last ten year period” (id.)), and 28 (which asks him to state “the address of all residential real estate currently owned by [him]” (id.)). These interrogatories are overbroad and vastly disproportionate to the needs of this case, see Fed. R. Civ. P. 26(b)(1), and Defendants also entirely ignore the case law in this District regarding when a party may be compelled to produce his tax returns, see, e.g., Delpilar v. Foodfest Depot, LLC, 15cv0459 (RA) (RLE), 2015 WL 9460141, at *1 (S.D.N.Y. Dec. 23, 2015). Nonetheless, as New York State law dictates that a candidate for the New York State Assembly must be a resident of the State for five years and a resident of the Assembly District for the 12 months immediately preceding the election,[6] and as Defendants seem to wish to advance a defense in this case that Plaintiff was not eligible to run in the Special Election because he did not meet the residency requirements,[7] this Court will allow limited discovery on the question of whether Plaintiff in fact met the State's residency requirements. Accordingly, Defendants’ application to compel a response to these Interrogatories is denied, except to the extent that Plaintiff is directed to identify his principal residence for the period from April 19, 2011 (five years before the scheduled Special Election) through February 3, 2016 (the date when Plaintiff withdrew his candidacy), and to produce documents sufficient to confirm that residency.[8] C. Defendants’ Third Set of Discovery Requests With respect to their third set of discovery requests, Defendants list another two categories of information that they claim to need from Plaintiff: information regarding (1) Plaintiff's history of engaging in other litigation, and (2) any complaints Plaintiff may have made against trial judges. (Def. Mem., at 3.) 1. Defendants’ Request for “Any Prior Personal or Corporate Litigation in New York State Courts” Defendants argue that they are entitled to the “detail[s]” of “any prior litigation to which [Plaintiff] was a litigant or otherwise,” which Defendants contend “is relevant to rebut Plaintiff[’s] claim of jurisdiction and to demonstrate Plaintiff's practice of engaging the courts in frivolous litigation.” This presumably relates to the following Interrogatories, in Defendants’ third set of requests: Interrogatory Nos. 1 (asking Plaintiff to “[s]tate in full detail each lawsuit of any source or nature in which [he] has been a party either as, including, but not limited to, a Plaintiff or Defendant or Claimant” (Def. Third Requests, Dkt. 68-4, at 19)), 4 (asking Plaintiff to “[s]tate in full detail each lawsuit of any source or nature in which any corporate entity in which [Plaintiff has] an ownership interest is currently a party ...” (id., at 20)), and 5 (asking Plaintiff to “[s]tate in full detail each lawsuit of any source or nature in which any corporate entity in which [Plaintiff] had but no longer [has] an ownership interest is currently a party ...” (id.)). *9 Defendants’ application to compel responses to these Interrogatories is denied. Plaintiff has alleged that Defendants engaged in federal constitutional violations, and he has invoked the Court's federal question jurisdiction. (See Compl. ¶ 10 (citing, inter alia, 28 U.S.C. § 1331).) Defendants have not demonstrated that the fact that Plaintiff may have participated in any other litigation is relevant to his claims here, or to any asserted defense.[9] 2. Defendants’ Request for Plaintiff's “Complaints Against Current Trial Judges” This category presumably refers to Interrogatory No. 6 in Defendants’ third set of requests; that Interrogatory calls for Plaintiff to “[s]tate in full detail each complaint that [he has] filed with any governmental entity against a sitting trial judge.” (Def. Third Requests, Dkt. 68-4, at 20.) In their motion, Defendants contend that “the requested information is relevant to rebut Plaintiff's allegation that due process is not available to him in New York State Courts.” (Def. Mem., at 3.) Defendants’ application to compel a response to this Interrogatory is denied, for the reasons set forth above, at n.7. D. Defendants’ Fourth Set of Discovery Requests Finally, with respect to their fourth set of discovery requests, Defendants contend that they need four more categories of information from Plaintiff: information regarding (1) the knowledge of Plaintiff's identified witnesses, (2) Defendants’ alleged constitutional violations, (3) Plaintiff's employment history and his claimed damages, and (4) the extent of Plaintiff's past absence from the United States. (Def. Mem., at 4-5.) 1. Defendants’ Further Request for Plaintiff's “Witness List” In Interrogatories Nos. 1 through 10, in their fourth set of discovery requests, Defendants ask Plaintiff to state whether 10 individuals previously identified by him as witnesses “will be testifying in [his] behalf in this action,” and to “state the knowledge of [sic] information” possessed by each of those witnesses “relevant to the subject matter of this action.” (Def. Fourth Requests, Dkt. 68-4, at 25-26.) To the extent Defendants are asking Plaintiff to state which of the identified witnesses will be called by him at trial, the request is premature, as Plaintiff need not list his trial witnesses until the preparation of the Joint Pretrial Order. In any event, Plaintiff has answered this portion of Defendants’ inquiry by stating, in opposition to their motion, that, “[a]t present, the only witness that Plaintiff intends to produce is the Plaintiff.” (Pl. Opp., at 5.) As for the information possessed by the witnesses identified by Plaintiff as likely having discoverable information, this Court refers to its ruling, above, as to Defendants’ earlier request for a “witness list.” (See Discussion, supra, at Section I(A)(2).) No further information will be required here. Accordingly, Defendants’ application to compel responses to these Interrogatories is denied. 2. Defendants’ Request for Information Regarding Claimed “Constitutional Violations” *10 This category presumably refers to Interrogatory Nos. 15 and 16, in Defendants’ fourth set of requests. Interrogatory No. 15 asks Plaintiff to “[s]tate in detail which rights, privileges, and immunities secured to [him] by the Fist [sic] and Fourteenth Amendment to the U.S. Constitution and 42 U.S.C. 1983 were deprived to [him] by each respective defendant as referenced in paragraph 62 of the Complaint.” (Def. Fourth Requests, Dkt. 68-4, at 26.) Interrogatory No. 16 similarly asks Plaintiff to “[s]tate in detail which rights, privileges and immunities secured to [him] by the Fourteenth Amendment to the U.S. Constitution and 42 U.S.C. 1983 were deprived to [him] by each respective defendant as referenced in paragraph 66 of the Complaint.” (Id., at 27.) Defendants argue in their motion that they “cannot possibly prepare an adequate defense without a more clear understanding of which rights, privileges and immunities they are respectively alleged to have violated[,] making the relevance of the demands indisputable.” (Def. Mtn., at 4.) Defendants’ application to compel a response to these interrogatories is denied. Even aside from the fact that these Interrogatories call for legal conclusions, this Court notes that, in paragraphs 61 and 65 of his Complaint, Plaintiff has already specified the purported rights that he claims were violated. Moreover, the body of the Complaint describes the alleged actions of the individual defendants that, according to Plaintiff, unduly burdened those rights. If Defendants are seeking to explore those factual allegations further, then they may do so by way of deposition. 3. Defendants’ Request for Plaintiff's “Employment History and Computation of Money Damages”_ This category presumably refers to Interrogatory No. 17 in Defendants’ fourth set of requests, which asks Plaintiff to “[d]escribe in detail [his] computation for money damages sought against each Defendant” (Def. Fourth Requests, Dkt. 68-4, at 27), and Interrogatory No. 18, which asks Plaintiff to “[s]tate [his] employment history for the last ten year period” (id.). According to Defendants, Plaintiff has never provided a damages computation, despite requests from Defendants on “multiple occasions.” (Def. Mtn., at 4.) To the extent, by way of Interrogatory No. 17, Defendants are seeking the information that Plaintiff is required to disclose pursuant to Rule 26(a)(1)(A)(iii) of the Federal Rules of Civil Procedure, the application to compel a response to that Interrogatory is granted. Pursuant to Rule 26(a)(1)(A)(iii), Plaintiff is directed to provide to Defendants a computation of each category of damages that he is claiming in this case, and to produce the documents (unless subject to privilege or work-product protection) on which each computation is based, including materials bearing on the nature and extent of injuries suffered. Defendants’ application to compel a response to Interrogatory No. 18 is denied as overbroad. If Plaintiff claims loss of income as a component of his damages, then Defendants may inquire at Plaintiff's deposition as to any employment that he lost as a result of the time spent on his campaign. 4. Defendants’ Request for Information Regarding Plaintiff's “Presence Outside the United States” Finally, Defendants apparently seek a response to Interrogatory No. 19, in their fourth set of requests, which asks Plaintiff to “[s]tate the amount of time spent by [him] in countries other than the United States of America during the last ten years.” (Def. Fourth Requests, Dkt. 68-4, at 27.) In their motion, Defendants contend that this information is relevant because “Plaintiff could not have maintained a status as a New York resident and eligible to be a member of the Party nor could he have maintained a viable or plausible campaign for elective office in the State of New York if he spent substantial time outside of the United States.” (Def. Mtn., at 5.) The New York State Election Law defines “residence” – an eligibility requirement for office (see supra, at 16 and n.6) – as “that place where a person maintains a fixed, permanent and principal home and to which he, wherever temporarily located, always intends to return,” N.Y. Election Law § 1-104(22). “Residency is generally a factual question, dependent upon the particular circumstances presented.” Glickman v. Laffin, 27 N.Y.3d 810, 814-15 (2016) (citation omitted). In this case, this Court notes that Plaintiff has represented to the Court that he does, on a regular basis, spend periods of time outside the United States, for purposes of receiving medical treatment. Under the circumstances, and as Defendants appear to wish to pursue a defense in this action based on Plaintiff's potential ineligibility for office (see Discussion, supra, at Section I(B)(2) and n.7), Defendants’ application to compel a response to Interrogatory No. 19 is granted, but only to the following limited extent, in view of the proportionality requirements of Rule 26(b)(1) of the Federal Rules of Civil Procedure: Plaintiff is directed to state the beginning and end dates of any trips, of more than two weeks in duration, that he traveled outside of the United States, during the period from April 19, 2011 through February 3, 2016. II. PLAINTIFF'S MOTION TO COMPEL (Dkt. 66) *11 Plaintiff's motion, for its part, requests that this Court (1) compel Defendants to answer Plaintiff's Request for Admissions (see Pl. Mtn., at 4), and (2) compel defendants Wright and McCadden to respond to certain interrogatories and document requests (see id., at 1-3). A. Requests for Admissions Plaintiff first asks this Court to compel Defendants to respond to his First Request for Admissions. (See Pl. Mtn., at 4.) Plaintiff states, however, that he served that discovery request on May 12, 2017 (id.), and this Court notes that his motion to compel was filed only one week later, on May 19, 2017 (see Dkt. 66). As the Federal Rules of Civil Procedure provide that a party may have 30 days to respond to a request for admissions, see Fed. R. Civ. P. 36(a)(3), this portion of Plaintiff's motion was filed prematurely. Moreover, if no written answer or objection to a request for admission is provided within 30 days of service of the request, then the matter is simply deemed admitted. (See id.) For these reasons, Plaintiff's motion to compel Defendants to answer his First Request for Admissions is denied. B. Document Requests and Interrogatories Plaintiff served on Defendants a single set of 75 discovery demands (including many with multiple subparts increasing the actual number of demands to well above one hundred), without differentiating between interrogatories and document requests. (See Plaintiff's First Set of Interrogatories and First Request for Production of Documents, dated Nov. 14, 2016 (“Pl. Requests”) (Dkt. 66, at 105-06 through Dkt 66-1, at 1-24).) For the most part, the requests contained in this set of demands are appropriately stated to be interrogatories, as they primarily ask for information, although a few of the requests also ask for supporting documents. In his motion to compel, Plaintiff challenges the adequacy of the responses of defendants Wright and McCadden to 16 of his requests, specifically, Requests Nos. 1, 4, 8-9, 12, 15, 18, 21, 31, 34-36, 41, 45, 49, and 52. (See Pl. Mtn., at 4 (stating that, although Wright and McCadden had “failed to answer nearly fifty requests without adequate justification,” Plaintiff had reviewed his requests and “unilaterally narrowed them” to 16, including subparts).) Each request that is a subject of Plaintiff's motion is addressed, in turn, below. 1. Plaintiff's Request No. 1 In his Request No. 1, Plaintiff asks Defendants to “(c)ite and provide copies of the governmental city, state, and federal authorities for conducting the nominating process for the Special Election.” (Pl. Requests, Dkt. 66-1, at 5.) Defendants responded to this Request by referring Plaintiff to “the applicable statutes demanded.”[10] As Defendants are not required to provide Plaintiff with copies of publicly available laws or regulations, and as Plaintiff apparently already has a copy of the Party Rules in his possession (see Compl. ¶ 44, and Ex. B thereto (Dkt. 2-1, at 5-16 (copy of the Party Rules))), Plaintiff's application to compel a further response to this Request by Wright and McCadden is denied, except to the extent that they are each directed to identify the statutes to which they have referred. 2. Plaintiff's Request No. 4 *12 Plaintiff's application to compel a further response to Request No. 4 is granted in part and denied in part. In this Request, Plaintiff asks Defendants to provide “each amendment to the [Party] Rules [... adopted September 29, 2015] made subsequent to its filing with the City or State Board of Elections.” (Pl. Requests, Dkt. 66-1, at 5.) Defendants responded by referring Plaintiff to the Party Rules. (See Def. Responses, Dkt. 66-1, at 27; McCadden Responses, Dkt. 66-1, at 37.) In his Complaint, however, Plaintiff alleges that, while he was provided with a copy of the Party Rules, he was also advised by the Deputy Director of Public Information for the New York State Board of Elections that he should “contact the MDP for recent amendments” and that, “[d]espite multiple requests, the MDP refused to provide” a copy of the Party Rules that included such amendments. (Compl. ¶ 44.) In light of this allegation, and as it is not clear that the Party Rules, with amendments, are publicly available, defendants Wright and McCadden are directed to produce to Plaintiff the amendments (if any so exist) to the Party Rules that were adopted during the period from September 29, 2015 (the date the Party Rules themselves were adopted) to February 3, 2016 (the date Plaintiff withdrew his candidacy (see Compl. ¶ 2)), to the extent a copy of any such amendments are within these defendants’ possession, custody, or control. Plaintiff's application to compel a response for any time frame after he withdrew his candidacy is denied for lack of relevance. 3. Plaintiff's Request No. 8 In his Request No. 8, Plaintiff seeks “all emails, letters, memoranda, notes or any other written material ... that in any way relates either to Silver or the nominating process to replace him,” for the period from “November 1, 2015 to November 16, 2016.” (Pl. Requests, Dkt. 66-1, at 5.) Although defendant McCadden responded that she was “not in possession of any of the written material as demanded” (McCadden Responses, Dkt. 66-1, at 37-38), in their separate response, Defendants collectively stated that they were “in the process of accumulating any such written material as demanded” (Def. Responses, Dkt. 66-1, at 27-28). This Court has not been made aware of whether any Defendants have since made any production, but, in any event, this Request – to the extent is seeks all communications or other writings relating, in any way, to Silver – is overbroad on its face. If, to date, defendant Wright has still not produced all documents in his possession, custody, or control specifically relating to the nominating process to replace Silver, from November 1, 2015 up to the date when Plaintiff withdrew his candidacy (February 3, 2016), then he is directed to do so. Otherwise, Plaintiff's application to compel a further response to this Request is denied. 4. Plaintiff's Request No. 9 In his Request No. 9, Plaintiff asks for “copies of all emails, letters, memoranda, notes or any other written material ... that relates in any way to [Plaintiff],” for the period from “November 1, 2015 to November 14, 2016.” (Pl. Requests, Dkt. 66-1, at 6.) As with Request No. 8, defendant McCadden responded by stating that she was not in possession of any such material (McCadden Responses, Dkt. 66-1, at 38), while Defendants collectively stated that they were in the process of “accumulating any such written material” (Def. Responses, Dkt. 66-1, at 28). In this instance, this Request appears reasonable, given that Plaintiff is claiming that the Defendants purposefully excluded him from participating as an election candidate, and Defendants’ communications, notes, or memoranda relating to Plaintiff are likely to reflect whether they were, in fact, trying to deter Plaintiff from running for an Assembly seat in the 65th Assembly District. Although it is evident from Plaintiff's submissions that he already has copies of a great deal of correspondence between himself and Defendants regarding his desired candidacy (see generally Compl., Exs. D-I, K, Q-S, V; Dkt. 68-1, at 57-98), it is unclear whether Defendants have fully produced all documents in their possession, custody, or control that are responsive to Plaintiff's Request. On this point, Defendants state, in opposition to Plaintiff's motion, that “Plaintiff has in his possession all documents of which Defendants are aware” (Def. Opp., at 1), but this is not the same as confirming that Defendants, and Wright in particular, have produced all responsive documents. Even if documents in Wright's hands are duplicative to documents held independently by Plaintiff, Plaintiff is entitled to obtain relevant documents from Wright's own files and from any other files over which Wright has control. *13 Accordingly, defendant Wright is directed to confirm, in writing, that he has produced all documents responsive to Plaintiff's Request No. 9 within his possession, custody, or control, or, if he has not done so, to make the requested production. 5. Plaintiff's Request No. 12 Plaintiff's Request No. 12 – to which Defendants objected, providing no substantive responses (see Def. Responses, Dkt. 66-1, at 28; McCadden Responses, Dkt. 66-1, at 38) – is not a single request, but rather a lengthy series of requests for information, or for answers to questions that variously relate to, inter alia, the identities, votes, and residencies of CCMs, and to the rules that governed their appointments and roles on or about February 7, 2016 (see Pl. Requests, Dkt. 66-1, at 8-12). As written, Request No. 12 includes nine subparts, labeled (a) through (i), each of which, in turn, includes additional subparts; indeed, Plaintiff breaks subpart (i) into 14 further subcategories of inquiries. (See id.) In its entirety, Request No. 12 is four pages long, and, by this Court's count, it includes at least 40 individual inquiries. In his motion, though, Plaintiff seeks to compel further responses to only portions of Request No. 12, specifically subparts (b), (d), (f), (i)(4), (i)(9), and (i)(10). (See Pl. Mtn., at 5-6.) These are addressed separately, below. a. Request No 12(b) In subpart (b) of his Request No. 12, Plaintiff asks Defendants to “provide a list” of CCMs who were “appointed” in the 65th Assembly District on or about February 7, 2016, together with “the date of their appointment(s), the reason for their appointment, and who appointed them.” (Pl. Requests, Dkt. 66-1, at 8.) Plaintiff further asks Defendants to “provide the authority for District Leaders or any other person(s)” to appoint CCMs and to “indicate the person(s) who authorized District Leaders or any other persons” to make such appointments. (Id., at 8-9.) Plaintiff concedes, however, that he already has in his possession a full list of the CCMs (see Compl. ¶ 36; id., Ex. K), as well as a copy of the Party Rules that govern vacancies of CCMs (see id. ¶ 44; id., Ex. B). Even apart from that, Plaintiff has not articulated how the inquiries posed in his Request No. 12(b) are relevant to his allegations that the Defendants suppressed his candidacy, much less that this discovery demand is proportional to the needs of the case. For these reasons, Plaintiff's application to compel production of the requested information from Wright and McCadden is denied. b. Request No. 12(d) In subpart (d), Plaintiff asks Defendants to explain how they “arrive[d] at concluding” that District Leaders could withhold the list of CCMs from the public and candidates for Assembly. (Pl. Requests, Dkt. 66-1, at 9.) This Request assumes that Defendants actually reached the stated conclusion, a fact they have not conceded.[11] Accordingly, this Request is improper, and Plaintiff's application to compel a further response is denied. c. Request No. 12(f) *14 In subpart (f), Plaintiff asks Defendants to state the number of CCMs “required for a quorum to conduct DEM. PARTY business” and to provide applicable authority. (Pl. Requests, Dkt. 66-1, at 9.) Plaintiff has not demonstrated how this inquiry is relevant to his asserted claims in this action. Nor is any relevance self-evident from the Complaint. Accordingly, his application to compel a response is denied. d. Request No. 12(i)(4), (9), and (10) Finally, in subpart (i), Plaintiff asks Defendants, in part, to “indicate each [CCM] that does not reside in the [ED] they represent” (Pl. Requests, Dkt. 66-1, at 10 (subpart (i)(4))), to state whether “the [Party] Rules require that [CCM] vacancies must be filled by enrolled Democrats that reside in the ED they represent” (id., at 11 (subpart (i)(9))), and to “[i]ndicate all efforts made by the DEM. PARTY to verify that each [CCM] resided in the address they provided to the DEM. PARTY” (id. (subpart (i)(10))). Although Plaintiff has not made an affirmative showing as to how these inquiries are relevant to his claims, it does appear, based on Defendants’ own motion to compel, that Defendants are taking the position that Plaintiff would only have been entitled to participate in the Party nominating process if he had a “qualifying primary residence.” (See Def. Mtn., at 3; see also Discussion, supra, at Section I(B)(2).) Therefore, at least to some extent, it appears that these inquiries are relevant to a defense that Defendants may be pursuing in this action. Accordingly, while this Court will not compel a response to what the Party Rules “require,” as those rules speak for themselves, Plaintiff's application to compel a response to the remaining portions of Request No. 12(i) is granted, to the extent that defendants Wright and McCadden are directed to identify those CCMs, if any, who, during the period from September 29, 2015 to February 3, 2016, did not reside in the ED that they represented, and to describe any formal procedure that was in place during that period to confirm the residence addresses of CCMs running for Assembly seats, if such information is within these defendants’ possession, custody, or control. Otherwise, Plaintiff's application to compel further responses to these Requests are denied. 6. Plaintiff's Request No. 15 In his Request No. 15, Plaintiff's asks Defendants to indicate each request received from Plaintiff “either by telephone or email, for the nominating process information.” (Pl. Requests, Dkt. 66-1, at 12-13.) Plaintiff also asks for the dates of such requests and “the authority for not providing information that was requested.” This Request is duplicative of Plaintiff's Request No. 9 (addressed above), as any request received in writing by the Defendants from Plaintiff would fall under “all emails, letters, memoranda, notes or any other written material ... that relates in any way to [Plaintiff].” For this reason, Plaintiff's application to compel further responses to this Request is denied. 7. Plaintiff's Request No. 18 In his Request No. 18, Plaintiff asks whether Defendants (presumably referring to the defendants Wright and McCadden), took the oath of office as required by the Party Rules. (See Pl. Requests, Dkt. 66-1, at 13.) Plaintiff also asks Defendants to “provide a signed, notarized or un-notarized, and dated copy of the oath that [they] took.” (Id.) Plaintiff has not demonstrated how this Request bears any relevance to the claims or defenses asserted in this action, and therefore his application to compel a response to this Request is denied. 8. Plaintiff's Request No. 21 *15 In his Request No. 21, Plaintiff asks each of the Defendants to identify their “duties and responsibilities regarding the nominating process to select a DEM. PARTY candidate for Assembly Member in the Special Election” and to provide authority for their responses. (Pl. Requests, Dkt. 66-1, at 13.) In response, Defendants merely refer Plaintiff to the Party Rules. (Def. Responses, Dkt. 66-1, at 29; McCadden Responses, Dkt. 66-1, at 39.) Given that Plaintiff is claiming in this case that Defendants conducted the nominating process for the Special Election unfairly, by purposefully disparaging Plaintiff's campaign, this Court finds the information sought by Plaintiff in this Request to be relevant to his claims, at least with respect to the time period in which the nominating process at issue took place. It may be, however, that any duties and responsibilities of defendants Wright and McCadden relating to that nominating process were wholly derived from the Party Rules in place at that time. If so, then these defendants need not supplement their response to this Request. If, however, Wrights’ and McCaddens’ duties and responsibilities regarding the nominating process for the Special Election were not fully set out in the Party Rules, or were derived, even in part, from any other source, then this Court directs Wright and McCadden to supplement their responses by describing the nature and scope of any of their duties and responsibilities not set out in the Party Rules, and by disclosing any additional applicable authority. 9. Plaintiff's Request No. 31 Plaintiff's Request No. 31 relates generally to Defendants’ responsibilities regarding complaints made to the Democratic Party by Party members, and, more specifically, regarding complaints made by Plaintiff. (See Pl. Requests, Dkt. 66-1, at 15.) The Request contains several subparts, but it appears from Plaintiff's motion that he is challenging Defendants’ response (which simply refers Plaintiff “to the [Party] Rules and applicable statutes”) to only some of those subparts. (See Pl. Mt., at 8.) First, Plaintiff seeks to compel a further response to the general question of whether it was within any of Defendants’ “responsibilit[ies] to receive and investigate complaints,” and, if not, to the question of who had such responsibility. (See id.) This portion of Request No. 31 appears relevant to Plaintiff's claims of being treated unequally during the nomination process and having his complaints about the alleged inequity ignored. (See Compl. ¶ 51-54.) Accordingly, defendants Wright and McCadden are directed to supplement their responses to this portion of the Request, to cite with specificity the “applicable statutes” to which they referred in their responses, and, to the extent the particular information requested cannot be fully discerned from the cited authority, to provide a direct response to the questions posed. Second, Plaintiff seeks to compel a further response to subparts (a), (b), and (c) of this Request. In these subparts, Plaintiff asks whether Defendants “receive[d] any complaints” from Plaintiff (Pl. Requests, Dkt. 66-1, at 15 (subpart (a))), whether the complaints were investigated and, if Plaintiff's complaints were not investigated, why no investigation was conducted (see id., (subpart (b))), and for any complaint submitted by Plaintiff that was investigated, a copy of any determinations reached after investigation (see id., (subpart (c))). These requests also appear relevant to Plaintiff's claims of unequal treatment, but, to the extent the requests call for the production of documents, the requested documents would already be subject to production in response to Request No. 9, discussed above (calling for production of copies of all “written material ... that relates in any way to [Plaintiff]”). To the extent these portions of the request Request call for information that would not necessarily be reflected in produced documents, and that can be ascertained by defendants Wright and McCadden after reasonable inquiry, these defendants are directed to supplement their responses to supply the requested information. For example, if any written complaints by Plaintiff were received by Defendants but not retained, then the responses should so state. Similarly, if any complaints by Plaintiff were investigated, but the results were not memorialized in a written determination, then the responses should explain this. Finally, if Defendants received any complaints from Plaintiff that were not investigated, then the response should set out the reasons for this. 10. Plaintiff's Request No. 34 *16 In his Request No. 34, Plaintiff asks Defendants to “describe how [they] conducted, coordinated, managed, controlled, or in any way supervised the nominating process for the Special Election,” and to produce “all documentation that indicates that [they] were authorized to supervise, coordinate, or manage” that process. (Pl. Requests, Dkt. 66-1, at 15.) To the extent this Request seeks information beyond that called for in Request No. 21, discussed above, Plaintiff's application to compel a further response is denied. An interrogatory that asks a party to “describe how” it took certain actions is not a “more practical method of obtaining the information sought” than a deposition, and thus the request is improper. Local Civ. R. 33.3(b). On this point, this Court notes that it sees no reason here to extend special consideration to Plaintiff because of his pro se status, given that he has secured the assistance of pro bono counsel for the purpose of conducting depositions. 11. Plaintiff's Request No. 35 Plaintiff's Request No. 35 asks Defendants whether it was their “responsibility to provide candidates competing for Assembly Member in the Special Election with necessary information,” and if not, to indicate who had that responsibility. (Pl. Requests, Dkt. 66-1, at 16.) As Plaintiff claims that he was denied information about the nominating process, in an effort by Defendants to suppress his candidacy (see Compl. ¶¶ 45, 46), this Court finds that this Request is relevant to his claims. Defendants, once again, answered this Request by merely referring to “the [Party] Rules and applicable statutes.” (Def. Responses, Dkt. 66-1, at 30; McCadden Responses, Dkt. 66-1, at 40.) Defendants Wright and McCadden are directed to supplement their responses by specifying the statutes to which they were referring, and by providing a direct answer to the questions posed, unless the responsive information can be fully derived from the Party Rules and statutes in question. 12. Plaintiff's Request No. 36 In his Request No. 36, Plaintiff asks whether Defendants provided information about the Special Election, including the “list of [CCMs], nominating forms,[12] notification of meetings, and other necessary information,” simultaneously to each candidate, including himself. (Pl. Requests, Dkt. 66-1, at 16.) If Defendants did provide this information simultaneously to each candidate, then Plaintiff additionally asks for the date when this was done; if the information was not provided simultaneously to each candidate, then Plaintiff asks Defendant to explain why this was not done. (See id.) This Request is relevant to Plaintiff's claims because the answers could show whether, as he claims, Defendants were treating him differently than other candidates for the open Assembly seat, and, here, Defendants’ near-standard responses of referring Plaintiff “to the [Party] Rules and applicable statutes” (Def. Responses, Dkt. 66-1, at 30; McCadden Responses, Dkt. 66-1, at 40) are plainly inadequate. Plaintiff, however, has not described what “other necessary information” he is referring to, and it is unclear whether Plaintiff is claiming that Defendants withheld from him any information other than the list of CCMs, nominating forms, and notifications of meetings. Accordingly, to the extent they have knowledge of the information or can ascertain it through reasonable inquiry, defendants Wright and McCadden are directed to respond to Request No. 36 by stating: (1) whether Defendants provided the list of CCMs, nomination forms, and notifications of meetings simultaneously to all candidates seeking the Democratic Party nomination for the Special Election for the 65th Assembly District; (2) if so, then the date when that information was provided to the candidates, and (3) if not, then the explanation for this. 13. Plaintiff's Request No. 41 *17 Plaintiff's Request No. 41, like his Request No. 12, is quite lengthy, containing multiple subparts and sub-subparts, and, in this instance, Plaintiff seeks to compel defendants Wright and McCadden to supplement their response to the entirety of the Request. (See Pl. Requests, Dkt. 66-1, at 16-18; Pl. Mtn., at 9-11.) Each of the portions of Request No. 41 relate, in some way, to Defendants’ scheduling and/or holding of meetings with the candidates for Assembly Member in the Special Election, or with the candidates’ representatives. In general, the Request asks whether Defendants or anyone else in the Democratic Party scheduled a meeting with candidates on February 3, 2016 or on any other dates; whether any such candidate meetings were authorized by defendant Wright, by defendant McCadden, or by an individual named Johnson;[13] the names of those who attended any such meetings; what was discussed at any such meetings; what information was provided to the attendees of any such meetings; whether Plaintiff was notified of any such meetings; and whether anyone gave instructions that Plaintiff not be so notified. (See Pl. Requests, Dkt. 66-1, at 16-18.) The Request also calls for the production of certain documents, including, for any candidate meetings, copies of any meeting notifications sent to the candidates, meeting minutes, and any forms or other written information provided to those in attendance. (See id.) Defendants responded to the Request by merely stating that they “have no knowledge of the actions of other people.” (Def. Responses, Dkt. 66-1, at 30; McCadden Responses, Dkt. 66-1, at 40.) As framed, some of the sub-parts to Request No. 41 are redundant.[14] The Request is also overbroad, as it is not limited to a time frame, and any meetings that took place after Plaintiff withdrew his candidacy would have no bearing on Plaintiff's claims that Defendants burdened his ability to compete in the election process. Further, to the extent the Request calls for Defendants to “[d]escribe in detail what was discussed” at any meetings, the Request is improper under Local Civil Rule 33.3(b), as a deposition would be a more practical way of obtaining the information sought than an interrogatory. Nonetheless, the basic question of whether Plaintiff was intentionally shut out of any meetings held for the benefit of candidates for the Special Election is relevant to his claim that Defendants treated him differently than other candidates and thereby hindered his ability to compete fairly with those other candidates. Accordingly, Plaintiff's application to compel further responses to this Request is granted, to the extent that defendants Wright and McCadden are directed to provide the following information, if known or ascertainable upon reasonable inquiry, regarding any scheduled or conducted meetings with Democratic Party candidates for the Assembly seat in the Special Election, up to the date that Plaintiff withdrew his candidacy: (1) whether Defendants or anyone else scheduled any such meetings and, if so, the dates when they were scheduled; (2) whether any such meetings were actually held and, if so, the dates when they were held; (3) whether written notice of such meetings was given to each of the candidates, including Plaintiff; (4) the identity of any person(s) with the responsibility for giving candidates notice of such meetings; (5) whether Defendants or anyone else instructed that notice of any such meetings be withheld from Plaintiff (identifying any person who gave such instruction, if given); and (6) the identities of the attendees at any such meetings, including their names and, if known, their candidate affiliations. In addition, with regard to the same type of meetings and for the same time period, defendants Wright and McCadden are directed to produce the following documents, if within their possession, custody, or control: (1) copies of meeting notifications sent to candidates, including Plaintiff; (2) copies of any internal communications or memoranda regarding whether meeting notifications should be sent to candidates; (3) copies of meeting minutes; and (4) copies of any materials provided to candidates or their representatives at the meetings. If no such documents exist, or if no such documents are within these defendants’ possession, custody, or control, then the response should so state. 14. Plaintiff's Request No. 45 *18 In his Request No. 45, Plaintiff asks whether Defendants “discussed [Plaintiff's] candidacy for Assembly Member with anyone.” (Pl. Requests, Dkt. 66-1, at 19.) In addition, Plaintiff asks Defendants to indicate each person with whom they discussed Plaintiff's candidacy, to state the date of each discussion, and to “describe, in detail, each discussion.” (See id.) Finally, Plaintiff asks Defendants to produce copies of all “emails, letters, memoranda, notes, and any other written material related to these discussions.” (Id.) Defendant McCadden has responded to this Request by indicating that she did not discuss Plaintiff's candidacy (McCadden Responses, at 40), while Defendants collectively responded that they were “in the process of researching the demand” (Def. Responses, Dkt. 66-1, at 31). Document Request No. 9, discussed above, would cover any documents requested here. As to the remainder of the Request, this Court notes that interrogatories are not a practical means to obtain details of oral discussions, and, for this reason, this Court will not compel defendant Wright to provide a further response. See Local Civ. R. 33.3(b). Plaintiff is free to seek such information by way of depositions, with the assistance of pro bono counsel. 15. Plaintiff's Request No. 49 In his Request No. 49, Plaintiff asks Defendants whether “District Leaders of the 65th AD have the authority to withhold the list of the [CCMs] from the public or candidates for public office,” and to identify the authority for any affirmative response. (Pl. Requests, Dkt. 66-1, at 19.) Plaintiff has not demonstrated how the information sought by this Request is relevant to any claim or defense that has been asserted in the action. Nor is the relevance evident to this Court based on its review of the pleadings, given that neither Wright nor McCadden is alleged to have been a District Leader when, according to Plaintiff, they burdened his constitutional rights. (See Compl. ¶¶ 15 (identifying defendant Wright as County Leader), 17 (identifying defendant McCadden as Executive Director of the NYCDC).) Plaintiff's application to compel a further response to this Request is therefore denied. 16. Plaintiff's Request No. 52 Finally, Plaintiff seeks to compel a further response to his Request No. 52, which asks whether Wright, Johnson,[15] or McCadden has “the authority to withhold the list of [CCMs] from candidates or the public” and to identify the authority for any affirmative response. (Pl. Requests, Dkt. 66-1, at 20.) With respect to the authority of Johnson, this Court again – as with Request No. 49 – perceives no relevance to Plaintiff's Request. In contrast, however, the relevance of Plaintiff's inquiry as to defendants Wright and McCadden is apparent, given that Plaintiff has specifically alleged that these defendants withheld from him information, including a list of CCMs, in order to suppress his candidacy for the Assembly. (See Compl. ¶¶ 43, 45.) Defendants again responded to Plaintiff's Request by referring Plaintiff “to the [Party] Rules and the applicable statutes.” (Def. Responses, Dkt. 66-1, at 31; McCadden Responses, Dkt. 66-1, at 41.) Plaintiff's application to compel further responses is granted to the extent the Request relates to defendants Wright and McCadden, and is otherwise denied. Defendants Wright and McCadden are directed to specify the statutes to which they were referring in their initial response, and to provide a direct answer to the question posed (limited to the time period from January 30, 2016 (the date when, according to Plaintiff, the Special Election was ordered by Governor Cuomo (see Compl. ¶ 4)) to February 3, 2016 (the date when Plaintiff withdrew his candidacy (Compl. ¶ 2)), unless the responsive information can be fully derived from the Party Rules and statutes in question). III. DISCOVERY SCHEDULE *19 In light of the above, and upon this Court's consideration of the motion of Plaintiff's limited-appearance pro bono counsel for an extension of the fact discovery period to allow for depositions to be conducted following this Court's ruling on the parties’ motions to compel (see Georgescu Mtn.),[16] the discovery schedule for this action is modified as follows: 1. All supplemental interrogatory responses and document production required by this Order shall be served no later than March 30, 2018. 2. No party may serve any additional interrogatories or document requests absent stipulation by the parties or advance leave of Court. Any application to this Court to permit such further discovery must be based on a showing that the additional requests are relevant to claims or defenses raised in this action, are proportional to the needs of the case, and could not have been anticipated earlier, despite reasonable diligence. 3. The deadline for the completion of all fact discovery, including depositions, is extended to April 30, 2018. This deadline should be considered final, as this Court does not anticipate granting any further discovery extension. CONCLUSION For all of the foregoing reasons, Defendants’ motion to compel further discovery from Plaintiff (Dkt. 65) and Plaintiff's motion to compel further discovery from Defendants (Dkt. 66) are both granted in part and denied in part, as set forth herein. The motion by Plaintiff's limited-appearance pro bono counsel for an extension of the discovery period (Dkt. 72) is granted, as set out above. Footnotes [1] In its Answer to the Complaint, the MDP appears to suggest that it is synonymous with the NYCDC (see Verified Answer of “the New York County Democratic Committee, also named herein as the Manhattan Democratic Party,” dated Aug. 15, 2016 (“MDP Ans.”) (Dkt. 42)), although the NYCDC also filed a separate Answer (see Verified Answer of “the New York County Democratic Committee,” dated Aug. 15, 2016 (“NYCDC Ans.”) (Dkt. 41)). [2] This motion was improperly filed as two separate motions, under a single docket number: (1) a motion “for discovery” and (2) a motion “to compel.” (See Dkt. 65.) This Court understands it to be a single motion, to compel further discovery responses by Plaintiff, and will treat it as such. [3] Silver's conviction was vacated on appeal in July 2017, and the matter is currently scheduled for a retrial on April 16, 2018. (See Dkts. 326, 254, in 15cr00093 (VEC).) [4] Plaintiff's opposition was apparently timely delivered to the Court's Pro Se Office for filing on June 2, 2017, and hence the Docket shows a June 2 filing date, even though the submission was not entered on the Docket until June 5, 2017. (See Dkt. 68; see also Letter to the Court from Plaintiff, dated June 8, 2017 (Dkt. 71) (explaining this).) [5] Unless otherwise indicated, the page number references cited to particular Docket entries are to the numbers affixed to the filed documents by the Court's Electronic Case Management (“ECF”) system. [6] See N.Y. Constitution Art. III, § 7; N.Y. Public Officers Law § 3; see also http://www.elections.ny.gov/RunningOfficer.html. [7] Based on Defendants’ motion, this Court assumes that Defendants are pursuing such a defense, even though they did not explicitly plead a defense based on Plaintiff's lack of eligibility for office. Rather, in their Answers, Defendants only pleaded (1) a non-specific affirmative defense based on Plaintiff's alleged failure “to state a claim,” and (2) an affirmative defense based on the Court's alleged lack of subject matter jurisdiction. See Verified Answer of Keith Wright, dated Aug. 23, 2016 (Dkt. 39), Verified Answer of Cathleen McCadden, dated Aug. 15, 2016 (Dkt. 40), MDP Ans., NYCDC Ans. (collectively, “Def. Answers”). [8] This Court notes that, in his opposition to Defendants’ motion, Plaintiff provides an address in Manhattan, and states that, “[s]ince 1971,” he “has resided at the same address.” (Pl. Opp., at 6.) Despite this statement in opposition, Plaintiff is directed to provide his residency information for the relevant period in the form of a verified interrogatory response, together with supporting documentation. [9] This Court notes that Plaintiff has also alleged, in his Complaint, that he seeks “venue” in this Court “as the result of the appearance of a conflict-of-interest” because, according to Plaintiff, the New York State Supreme Court justices were nearly all elected with the support of the MDP, and the MDP has “continued influence” over them “through their reelection campaigns and support of justices [who] seek elevation to the appellate courts.” (Compl. ¶ 12.) The existence of any such “influence” or “conflict” would not be relevant to a venue analysis under 28 U.S.C. § 1391, and would certainly not relevant to the question of whether this Court has subject matter jurisdiction over this action. This Court thus sees no reason to permit discovery into the matter. [10] Attached to Plaintiff motion to compel are copies of two responses by Defendants to his discovery requests. First, is a document entitled “Defendants’ Responses to Plaintiffs’ First Set of Interrogatories and First Request for Production of Documents,” dated January 11, 2017; this response purports to have been made by “Defendants,” and is verified by defendant Wright (herein, “Def. Responses”) (Dkt. 66-1, at 26-34). Second, is a document bearing the identical name, dated March 31, 2017; in the body of this response, however, it purports to have been made only by defendant McCadden, and is verified by McCadden (herein “McCadden Responses”) (Dkt. 66-1, at 36-44). In many, but not all, respects, as with the responses to Plaintiff's Request No. 1, the discovery responses contained in the two documents are identical. [11] In his Complaint, Plaintiff alleged that District Leaders “conspired ... to unreasonably withhold the county committee member list to suppress candidate competition.” (Compl, ¶ 35.) Each of the Defendants separately filed a Verified Answer to the Complaint (Dkts. 39 (Wright), 40 (McCadden), 41 (NYCDC), and 42 (MDP) (collectively, “Def. Answers”)), in which each denied “in whole or in part those allegations set out in paragraphs ... 35 ... of the [C]omplaint” (see Def. Answers ¶ 1). [12] By “nomination form,” Plaintiff is apparently referring to the voter proxy form that Plaintiff alleges the Defendants intentionally withheld from him during the nomination process for the Special Election. (See Compl. ¶ 50.) [13] This is presumably intended to refer to Jeanine R. Johnson, who was named by Plaintiff in a proposed Amended Complaint that he never sought, or was granted, leave to file, and that is not the operative pleading in this case. (See Dkt. 60.) [14] For example, Plaintiff asks three times, with only slight variations in wording, for the dates of any meetings that Defendants held with the candidates for Assembly Member, the location of such meetings, who attended such meetings, and what was discussed at such meetings. [15] See supra, at n.13. [16] Plaintiff's limited-appearance pro bono counsel states in her motion that she attempted to work with Defendants’ counsel to schedule depositions, but that Defendants’ counsel took the position “that scheduling depositions [was] premature[,] as an order on the motions to compel had not yet been issued.” (Georgescu Mtn.) Defendants filed no opposition to the motion for an extension of the discovery period; nor, according to Plaintiff's limited-appearance counsel, did Defendants respond to her proposal to file a joint request for an extension. (See id.)