The difference between interrogatories seeking information, and requests for production of documents is that they do not have a similar impact, and the rule allowing the requests for admissions to be deemed admitted is different than those other two categories of discovery.
In the first two, the court will order the answers on pain of contempt of court, or other penalties which are also available.
Would you, knowing what you know in the Berg v. Obama case, believe the judge would allow this laxity in production?