. A, Resp. No. 19. A failure to respond or object to a discovery request in a timely manner waives any objection which may have been available. See Cohalan v. Genie Industries, Inc., 276 F.R.D. 161, 163 (S.D.N.Y. 2011) (noting that failure to timely object to discovery request waives objections and collecting cases); Smith v. C