Extract to table

It is not sufficient for the requesting party to assert, in conclusory fashion, that the requested materials "may" be relevant; rather, the requesting party must make an affirmative showing of the specific relevance of the materials sought and explain why the discovery already provided is inadequate

1999) (recognizing that discovery requests must be "reasonably calculated to lead to the discovery of admissible evidence" and affirming the trial court's discretion to limit overbroad requests)

To be probative of pretext, comparator evidence must involve employees who are "similarly situated in all material respects" to the plaintiff

2002) (holding that comparator employees must be "directly comparable to the plaintiff in all material respects"); Humphries v

Discovery must be targeted and specific, not speculative