In Mendelowitz v. Xerox Corp., 169 AD2d 300, 303-04, 573 N.Y.S.2d 548 (1st Dept 1991), the plaintiff requested, among other things, "[c]opies of any books, articles or other medical information concerning the effects of asbestos exposure on human health and safety in the possession of the defendant prior to January 1, 1979", that date coinciding with the plaintiff's decedent's retirement. The plaintiff offered to withdraw the request if the defendant allowed the plaintiff access to the library maintained by the defendant in Rochester, New York. The defendant rejected this offer and moved for a protective order, which the trial court granted. The First Department explained that a demand for the production of documents must specify the items sought with reasonable particularity, that the burden of proving specificity is on the requesting party, and that the utilization of the language "any and all" is usually an indication of a lack of the requisite specificity.