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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 11 of 27 time of 11 hours and 52 minutes. A total of 787 questions were posed to Ms. Maxwell in the second deposition. Ms. Maxwell answered every question posed to her that fell within the scope of the June 20 Order, many that were outside the scope, and countless questions that had been asked and answered in her first deposition. It is difficult to discern precisely what questions Plaintiff is complaining about in her Motion because of her generalized and non-specific complaints. Plaintiff fails to cite to a single instruction not to answer that 1) falls within the scope to the Court’s Order and 2) that was not answered when properly rephrased to fall within the scope of the Order. S.D.N.Y. Local Rules require that: A party seeking or opposing relief under Fed. R. Civ. P. 26 through 37 inclusive, or making or opposing any other motion or application, shall quote or attach only those portions of the depositions, interrogatories, requests for documents, requests for admissions, or other discovery or disclosure materials, together with the responses and objections thereto, that are the subject of the discovery motion or application, or that are cited in papers submitted in connection with any other motion or application. See also Civil Local Rule 37.1. The failure to comply with Rule 37.1 and set forth the particular questions or responses Plaintiff claims are deficient is “enough to require denial of the motion.” Sibley v. Choice Hotels Int'l, No. CV 14-634 (JS) (AYS), 2015 WL 9413101, at *5 (E.D.N.Y. Dec. 22, 2015) (denying motion to compel where party failed to identify the specific questions and responses to interrogatories claimed deficient); see also Kilkenny v. Greenberg Traurig, LLP, No. 05 CIV. 6578NRB, 2008 WL 371808, at *1 (S.D.N.Y. Feb. 7, 2008) (denying motion to compel where specific questions and objection were not provided, noting rule 37.1 is “This is not an academic or ritual requirement. ... Court cannot be tasked with performing the functions of Kilkenny's legal counsel [by identifying claimed deficiencies] and thereby seen as advocating for one party over another.”; Frattalone v. Markowitz, No. 91 CIV. 5854 (LMM), 1994 WL 494878, at *3