Defendant Cell Crete Corp.’s Motion to Compel Plaintiff to Produce Documents. Defendant/Cross-Complainant Cell Crete Corp. propounded upon plaintiff/cross-defendant Weber General Engineering requests for production of 15 categories of documents. Weber General Engineering responded with a list of the following boilerplate, general objections: attorney-client privilege; work product doctrine; relevancy; the requests are premature, unduly burdensome, and oppressive at this stage of the litigation; and Weber General Engineering does not concede the relevance of, materiality of, or admissibility of any information requested or provided. Weber General Engineering also made some objections in response to specific requests in addition to the general objections and concluded with the statement that subject to and without waiving such objections plaintiff will produce non-privileged, relevant, responsive documents within its possession, custody and control if such documents exist. Defendant Cell