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P asserts claims under title 42, section 1983 stemming from the death of her son, while he was incarcerated in the D County Jail. P seeks to compel D to respond to the following discovery request: INTERROGATORY NO. 15: Please identify any written complaints concerning failure to provide medical treatment to inmates at the detention center for the ten years prior to the filing of this action. P argues these records are relevant to her allegations that D had an unconstitutional policy of denial of medical treatment to its prisoners and that Defendant Brandi Saulsberry was negligent in her supervision. D objected on the grounds that 'P's request is overbroad, unreasonably burdensome, not relevant, and not reasonably calculated to lead to the discovery of admissible evidence.' Further D claims it would have to review all inmate grievances, inmate requests to staff, lawsuits, and Notice of Tort Claims submitted by anyone for the past 10 years, and D objects to doing this. D did present evidence that since May 2011 D has been sued three times to the best of his knowledge for alleged denial of medical treatment. D argues that its response to Interrogatory 15 was responsive because P's request was phrased as 'any written complaints' rather than 'all written complaints.' By requesting 'any written complaints,' P is only requesting some of the written complaints that may exist.

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