In Dillard Dep't Stores, Inc. v. Hall, 909 S.W.2d 491, 492, 38 Tex. Sup. Ct. J. 1042 (Tex. 1995), the Court held the trial court's order was overly broad, because it required Dillard to produce every incident report filed between 1985 and 1990 in all 227 Dillard stores nationwide. Dillard, 909 S.W.2d at 492. The Court explained that "requests for document production may not be used simply to explore." Dillard, 909 S.W.2d at 492 (citing Loft v. Martin, 776 S.W.2d 145, 148, 32 Tex. Sup. Ct. J. 401 (Tex. 1998)).