and relevant to plaintiffs claims for damages. Because plaintiff does not maintain that he is unable to “readily identify the documents requested ... [or] that it would be unduly difficult to determine which documents fall within the scope of the request ... [plaintiffs] objections based on overbreadth are without merit.” Gen. Elec. Capital Corp. v. Lear Corp., 215 F.R.D. 637, 641 (D.Kan.2003). Plaintiff argues that defendant’s request for records concerning his application to take a state bar exam requires him to produce privileged documents. Plaintiff, however, has waived whatever privilege attached to those documents by bringing a lawsuit in which his employability as an attorney is central to the determination of damages. See Anderson v. Nixon, 444 F.Supp. 1195, 1200 (D.D.C.1978) (<HOLDING>). Plaintiffs contention that defendant violated
holding that where the interests of a newsman in preserving the anonymity of his sources clash with his responsibilities as a plaintiff and where the information sought to be protected goes to the heart of the defense the privilege must give way holding that the defense may present the entire conversation where it goes to the heart of the  defense holding that trial error in a civil case which went to the very heart of the defendants defense and was central to his defense could not be deemed harmless in the absence of any steps by the district court to mitigate the effects of the error holding at the 12b6 stage that the plaintiffs complaint when taken as true stated a claim for relief which might be granted even though the enforceability of the covenant  rests on factual questions such as whether the geographic effect of the clientbased restriction is excessive in light of the defendants actual contacts with customers the nature of his duties the level of his responsibilities the scope of his knowledge and other issues relating to how closely the geographic limits fit with his work for the plaintiff holding that a defendant must demonstrate that the governments intrusion upon his relationship with his attorney created a possibility of either injury to his defense or benefit to the government in order to establish a violation of the right to counsel