1) Yes, "overly broad" is an objection to a discovery request.
2) I agree that in order to have the best chance against an attorney/client privilege
, the request should be narrowly made.
3) Unless NJ has a law linking waiver of attorney/client privilege in fraud cases, and I doubt that they do, then I do not understand that claim.
4) I agree with your analysis--with my limited knowledge of NJ law--that the fraud exception applies to the party against whom the request is made not the opposing party.
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