written discovery based upon all information reasonably available, subject to objections and privileges.” Tex.R. Civ. P. 193 cmt. 1. It permits a party to object to discovery as overbroad and to refuse to comply with it entirely. Id. at cmt. 2 (citing Loftin v. Martin, 776 S.W.2d 145 (Tex.1989) (orig. proceeding)). “A central consideration in determining overbreadth is whether the request could have been more narrowly tailored to avoid including tenuous information and still obtain the necessary, pertinent information.” CSX, 124 S.W.3d at 153. “[Discovery may not be used as a fishing expedition or to impose unreasonable discovery expenses on the opposing party.” Alford Chevrolet-Geo, 997 S.W.2d at 181 (citing K Mart Corp. v. Sanderson, 987 S.W.2d 429, 431 (Tex.1996) (orig. proceeding) (<HOLDING>)); see also In re Am. Optical Corp., 988 S.W.2d
holding that the trial court must ensure that the requests are tailored to the specific action and that discovery requests that reflect a mere fishing expedition should not be allowed holding that a discovery exception to a statute of limitation applies only to the discovery of facts not discovery of the law holding that not only must discovery requests be reasonably tailored to include only matters relevant to case but discovery requests may not be used as fishing expedition or to impose unreasonable discovery expenses on opposing party holding that when the nonmoving party requests a delay in ruling on a summary judgment motion until further discovery may be completed the party must demonstrate the likelihood that further discovery will uncover additional relevant evidence holding that the defendants discovery requests were untimely because they were not served in time for the responses to be due before the discovery deadline