ries, 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. Conway Organization, Inc., 154 F.R.D. 73 (S.D.N.Y.1994). Plaintiff cannot and does not contest that the Settlement Agreement is relevant and must be produced. III. PLAINTI