In Anonymous v. High School for Envtl. Studies (32 AD3d 353 [1st Dept 2006]) the defendant never even provided a privilege log pursuant to CPLR 3122 and the Appellate Division determined that defendant's claims of privilege were insufficient as a matter of law (id. at 359). The defendant objected to each of plaintiffs document requests as "vague, confusing, overbroad, unduly burdensome and not likely to lead to information which is material and necessary to the prosecution of this matter" (id. at 355).