*1 Dear Counsel:

This case was referred to me for purposes of discovery on December 16, 2016. On August 15, 2017, Plaintiff, Sharon Bost (“Plaintiff”), filed a motion to compel supplemental interrogatory responses (ECF No. 190). On August 29, 2017, Defendants, Elizabeth Obadina, Andria Wiggins, Ebere Ohaneje, Anike Ajayi, Najma Jamal. Karen McNulty, Jocelyn El-Sayed, Getachew Afre, and Oby Atta (collectively, the “Individual Medical Defendants”), filed a response in opposition to Plaintiff’s motion to compel, asserting that their responses were sufficient and need not be supplemented (ECF No. 199). On September 10, 2017, Plaintiff filed a reply (ECF No. 205). In addition, on September 3, 2017, Plaintiff filed a motion to compel a one hour Rule 30(b)(6) deposition for late-produced medical record metadata (ECF No. 200). On September 6, 2017. in two separate filings, Defendants, Wexford Heath Sources, Inc. (“Wexford”) and the Individual Medical Defendants, and Defendants, Carolyn Atkins. Ricky Foxwell, Gwendolyn Oliver, Shavella Miles, Carol Harmon, Carol McKnight, and Valerie Alves (collectively, the “Custody Defendants”), filed responses (ECF Nos. 202 and 203, respectively). Plaintiff replied on September 11, 2017 (ECF No. 207). This issue is now fully briefed and no hearing is necessary. Loc.R. 105.6 (D.Md. 2016). For the reasons that follow. Plaintiff’s motion to compel supplemental interrogatory responses (ECF No. 190) is GRANTED IN PART AND DENIED IN PART and Plaintiff’s motion to compel a one hour deposition for late-produced medical record metadata (ECF No. 200) is GRANTED.

This case arises from an action brought by Plaintiff on behalf of the Estate of Fatima Neal. Neal was a detainee at the Baltimore City Detention Center (“BCDC”) from the date of her initial incarceration beginning on October 30, 2012 to the date of her death on November 4, 2012. Plaintiff’s action alleges that members of the medical staff at the BCDC infirmary and others ignored Neal and refused to arrange transport to nearby Johns Hopkins Hospital for treatment despite evidence that Neal had suffered multiple strokes over the course of the four days that she was under their care. Plaintiff asserts that from November 1, 2012, when Neal was placed in the infirmary, to November 4, 2012, when she died. Neal displayed various symptoms of stroke, including extreme headache, disorientation. loss of vision, confusion, erratic behavior, one-sided weakness and paralysis, inability to ambulate, and loss of control of bodily functions.

A. Plaintiff’s Motion to Compel Supplemental Interrogatory Responses

Plaintiff first seeks an order from this Court to compel supplemental interrogatory responses. Specifically. Plaintiffs challenge Defendants’ objections to the following responses to interrogatories: Interrogatories Nos. 1, 2, and 5 by the Individual Medical Defendants; Interrogatory No. 4 by Afre, El-Sayed, and Wiggins; and Interrogatory No. 7 by Afre, El-Sayed, Wiggins, Obadina, Ohaneje, Jamal. Ajayi, and Atta. This Court will address each of these disputes in turn.

*2 Typically, contention interrogatories are permissible. Fed.R.Civ.P. 33(c); see also Fed.R.Civ.P. 33(a)(2) (“An interrogatory may relate to any matter that may be inquired into under Rule 26(b). An interrogatory is not objectionable merely because it asks for an opinion or contention that relates to fact or the application of law to fact ....”); Jayne H. Lee, Inc. v. Flagstaff Indus. Corp., 173 F.R.D. 651, 652 (D.Md. 1997) (“Properly drafted, ‘contention interrogatories,’ ... can help pin down an opponent’s legal theories in a case as well as the primary facts supporting them.”). “An interrogatory may properly inquire into a party’s contentions in the case and the factual basis therefor. The defendant is entitled to know the factual basis of plaintiff’s allegations and the documents which the plaintiff intends to use to support those allegations.” Ayers v. Cont’l Cas. Co., 240 F.R.D. 216, 226 (N.D.W.Va. 2007) (quoting Cont’l Ill. Nat’l Bank & Tr. Co. of Chi. v. Caton, 136 F.R.D. 682, 684 (D.Kan. 1991)). A motion to compel can be denied if the circumstances render compelling an answer to the question otherwise unnecessary. See Oliver v. Comm. for the Re–Election of the President, 66 F.R.D. 553, 555 (D.D.C. 1975); In re Folding Carton Antitrust Litig., 83 F.R.D. 132, 134 (N.D.III. 1979); Cabana v. Forcier, 200 F.R.D. 9, 17 (D.Mass. 2001); Tillman v. Lincoln Warehouse Corp., No. 83 CIV. 5381 (CSH). 1987 WL 7933, at *3 (S.D.N.Y. Mar. 13, 1987).

1. Interrogatories Nos. 1 and 2

Interrogatories Nos. 1 and 2 both regard Neal’s stroke, and because they concern the same topic, these interrogatories can be addressed collectively. Interrogatory No. 1 seeks information about each Defendant’s position on when Neal suffered a stroke and the evidence they rely on for their position. ECF No. 190-4 at 1. In Interrogatory No. 2, Plaintiff questions Defendants on Neal’s first symptom of stroke in their view. Id. Defendants object to both of these interrogatories to the extent that they seek to shift the burden of proof, violate work-product protection, and “go[ ] far beyond” the Rule 26(a)(3) disclosures, and they adopt and incorporate four experts’ reports and deposition testimonies. E.g., ECF Nos. 190-7 at 2. Additionally, for Interrogatory No. 2, Defendants object that they “may be without personal knowledge sufficient to answer this Interrogatory” and that “symptom of stroke” is vague. E.g., id. at 3. For each interrogatory, Plaintiff contends that Defendants failed to raise valid objections and that their responses were insufficient. ECF No. 190-1 at 4. This Court agrees.

Regarding Defendants’ burden of proof objection, Defendants contend that they do not yet know how they will rebut Plaintiff’s case and the positions they will take on the issues and sub-issues. As Plaintiff’s third set of interrogatories were served in May 2017, only a few months before the close of discovery, Defendants’ argument fails. Plaintiff can properly ask Defendants, in interrogatories, to articulate the factual basis for their defense as they understand it. Accordingly, it was improper for Defendants to hedge that they may have knowledge about Neal’s first symptom. Instead, Defendants must supplement their response to state whether they have sufficient knowledge, and if so, state their position regarding what symptom Neal first exhibited and when. Defendants next contend that “symptom of stroke” is vague, yet the question itself is limited to what Defendants believe “in [their] view” was the first symptom Neal exhibited. “Symptom of stroke” is not so vague as to defy comprehension in the unique setting in which it is utilized by Plaintiff in her interrogatory.

In addition, where the interrogatories do not specifically inquire into an attorney’s mental impressions, conclusions, or legal theories or the content of a document protectable as work product, it is inappropriate to raise a work-product objection. Pouncil v. Branch Law Firm, 277 F.R.D. 642, 649 (D.Kan. 2011). Interrogatories Nos. 1 and 2 do not specifically request or inquire into the mental impression, conclusions, or legal theories of defense counsel nor do they ask for the content of any documents or materials that Defendants have shown to be protected work product.

*3 Moreover, for a contention interrogatory, simply directing the opposing party to documentation is inadequate. See Par Pharm., Inc. v. TWi Pharms., Inc., No. CCB-11-2466, 2012 WL 12548935, at *2 (D.Md. Oct. 4, 2012) (stating that a party’s response to contention interrogatories that merely referred to thousands of pages of documents would constitute “a shameless violation of Rule 33(d),” which requires that the responding party “specify the records that must be reviewed, in sufficient detail to enable the interrogating party to locate and identify them as readily as the responding party could”). A narrative response is required to articulate the basis for an answering party’s conclusion, where the answering party states that he or she reached the conclusion after reviewing the listed documents. Goldstein v. Berman, No. WDQ-12-2507, 2013 WL 1663177, at *1 (D.Md. Apr. 15, 2013). Thus, Plaintiff’s motion to compel a supplementary response to Interrogatories Nos. 1 and 2 is granted.

2. Interrogatory No. 4

Interrogatory No. 4 asks Defendants whether they performed a differential diagnosis on Neal during a five day period and any evidence related to performing differential diagnosis. ECF No. 190-4 at 2. Defendants reply that this interrogatory is unreasonably cumulative and duplicative because Plaintiff has already elicited a “yes” response to this question from the Defendants during their depositions. ECF No. 199 at 14–18. Plaintiff, on the other hand, argues that this information was not provided in Defendants’ depositions, and even if it was, Defendants may not refuse to answer an interrogatory with merely overlaps with deposition questions. ECF No. 190-1 at 13.

The Court has reviewed the deposition transcripts submitted and concludes that Interrogatory No. 4 is not unreasonably cumulative or duplicative as argued by Defendants. Although the depositions briefly addressed the general themes of the disputed interrogatories—namely, the performance of a differential diagnosis—they are insufficient as a substitute for answering the specific interrogatory at issue here. The Court finds that the deposition testimony does not sufficiently answer the interrogatory and therefore does not defeat Plaintiff’s motion to compel. Accordingly. Defendants shall provide responsive answers to these interrogatories. Plaintiff’s motion to compel Defendants to supplement their answer to Interrogatory No. 4 is granted.

3. Interrogatory No. 5

Plaintiff’s Interrogatory No. 5 asks whether Defendants contend that any witnesses who are former detainees of BCDC provided untruthful or inaccurate testimony and for any evidence supporting such a position. ECF No. 190-4 at 2. Defendants responded that this interrogatory sought answers protected from disclosure by the work-product doctrine and attorney-client privilege. E.g., ECF No. 190-7 at 4–5. For the same reasons already discussed above, Plaintiff’s Interrogatory No. 5 does not specifically request or inquire into the mental impression, conclusions, or legal theories of defense counsel nor does it ask for the content of any documents or materials that Defendants have shown to be protected work product or related to confidential communications between Defendants and their counsel.

Looking at the substance of Defendants’ answers, Defendants again fail to specifically direct Plaintiff to the documents which they allege contradict the former detainee witnesses. Furthermore, Defendants generalize the witnesses’ inconsistencies, only providing one instance where Plaintiff can determine which witness’s testimony is being challenged; otherwise. Defendants refer generally to “statements of several detainee witnesses.” See, e.g., id. at 5. Accordingly, Defendants must supplement their responses to Interrogatory No. 5.

4. Interrogatory No. 7

*4 Plaintiff’s Interrogatory No. 7 seeks information concerning Neal’s treatment for a stroke prior to noon on November 3. 2012 and any evidence of such treatment. ECF No. 190-4 at 2. Plaintiff asks this Court to order Defendants to submit a simple answer in order to simplify trial. ECF No. 190-1 at 16–17. This Court declines to do so because Defendants’ answers were responsive and demonstrated that they did not provide any treatment before noon on November 3, 2012. E.g., ECF No. 190-7 at 6. Therefore, Defendants need not supplement their responses to this contention interrogatory. The Motion to Compel is therefore denied as to Interrogatory No. 7.

B. Plaintiff’s Motion To Compel One Hour Rule 30(b)(6) Deposition Regarding Late-Produced Medical Record Metadata

Plaintiff next asks this Court to compel the Custody Defendants to produce a designee to sit for a one hour Rule 30(b)(6)[1] deposition regarding the meaning and interpretation of Neal’s medical record metadata, which they produced on the day before the discovery deadline. ECF No. 200-1 at 1. The metadata concerns Ms. Neal’s medical records, and, according to Plaintiff, they specifically show altered and newly added records. Id. at 1–2. Consequently, Plaintiff requests that this Court allow her to conduct a deposition in order to clarify the meaning of the metadata or. in the alternative, to depose three metadata witnesses disclosed by Defendants on the discovery deadline. Id. at 9–10. Defendants, in opposition, contend that Plaintiff was not diligent in pursuing the metadata of Neal’s electronic medical records because Defendants had already informed Plaintiff that another entity was likely the custodian of the metadata, and that the burden of a deposition after the discovery deadline had passed was too great. ECF No. 202 at 4; ECF No. 203 at 4–6. Plaintiff replies that she requested the metadata from the correct entities and that a one hour deposition would not be burdensome on Defendants. ECF No. 207 at 5, 9.

The discovery deadline in this case has passed, and the issues of reopening discovery and conducting an additional deposition lie within the discretion of the court. Vodrey v. Golden, 864 F.2d 28, 32 (4th Cir. 1988). To reopen discovery, Plaintiff must satisfy the good cause standard of Rule 16(b)(4) of the Federal Rules of Civil Procedure. The primary consideration of the court in addressing whether “good cause” has been shown under Rule 16(b) relates to the movant’s diligence. Montgomery v. Anne Arundel Cty., Md., 182 F.App’x 156, 162 (4th Cir. 2006) (per curiam). Lack of diligence and carelessness are the “hallmarks of failure to meet the good cause standard.” W. Va. Hous. Dev. Fund v. Ocwen Tech. Xchange, Inc., 200 F.R.D. 564, 567 (S.D.W.Va. 2001). “[T]he focus of the inquiry is upon the moving party’s reasons for seeking modification. If that party was not diligent, the inquiry should end.” Marcum v. Zimmer, 163 F.R.D. 250, 254 (S.D.W.Va. 1995) (emphasis omitted) (quoting Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)).

*5 Plaintiff has met these standards. In several of her discovery documents, Plaintiff requested information which would have included the metadata. In her requests for production filed with Wexford. BCDC, and the Individual Medical Defendants in May 2016, Plaintiff requested typed. computerized, electronic documents and electronically stored information, which included “other data,” relating to Ms. Neal. ECF No. 200-4 at 3–4, and in her November 2016 requests for inspection, Plaintiff requested access to BCDC’s computer system used by medical staff, ECF No. 200-5 at 2.[2] Then, in her July 14, 2017 letter, Plaintiff “reiterate[d]” her request that the Defendants provide the metadata of Plaintiff’s medical records. ECF No. 200-9 at 1. Defendants produced the metadata on August 14, 2017, nearly four weeks after the July 14, 2017 letter, ECF No. 200-8 at 1, and they wrote a letter to Plaintiff with the names of three individuals who may have knowledge about the creation of electronic medical records. ECF No. 202-7 at 2–3. On the same day that she received the metadata from the Custody Defendants, Plaintiff informed Defendants’ counsel that she had issued a notice for a one hour deposition to clarify the metadata information and said that she could be available for a deposition the next day, which would fall within the discovery deadline, or sometime later if the parties agreed to it. ECF No. 200-8 at 1, see also ECF No. 200-7 at 1–2. Thus, despite Defendants* arguments to the contrary, there is no indication that Plaintiff was not diligent in attempting to obtain all relevant documents, including electronic information such as the metadata, from Defendants. This Court has extended discovery deadlines to permit time for additional depositions. See, e.g., Humbert v. O’Malley, No. WDQ-11-0440, 2015 WL 1256458, at *3 (D.Md. Mar. 17, 2015). Accordingly, Plaintiff’s motion to compel a one hour deposition regarding the medical record metadata will be granted.

C. Conclusion

District courts enjoy substantial discretion in the management of discovery and whether to grant motions to compel. Lone Star Steakhouse & Saloon, Inc. v. Alpha of Va., Inc., 43 F.3d 922, 929 (4th Cir. 1995): LaRouche v. Nat’l Broad. Co., 780 F.2d 1134, 1139 (4th Cir. 1986); Clark v. Unum Life Ins. Co. of Am., 799 F.Supp.2d 527, 531 (D.Md. 2011). Thus, for the reasons set forth in this Court’s letter to counsel, Plaintiff’s motion to compel supplemental interrogatory responses (ECF No. 190) is GRANTED with respect to Interrogatories Nos. 1, 2, 4, and 5 and DENIED with respect to Interrogatory No. 7. and Plaintiff’s motion to compel a one hour deposition for late-produced medical record metadata (ECF No. 200) is GRANTED. For the forgoing reasons, within ten days of this order, Defendants must supplement their answers, as appropriate, to Plaintiff’s Interrogatories 1, 2, 4 and 5. Furthermore, the Court extends the discovery deadline in this case to October 20, 2017 in order to allow one additional deposition hour for the limited purpose of Plaintiff deposing a witness regarding Neal’s medical record metadata.

The Court continues to recommend that the parties work together to resolve any other outstanding discovery issues in order to ultimately bring this case to a final resolution. Despite the informal nature of this letter, it is an Order of the Court and shall be docketed accordingly.

Rule 30(b)(6) of the Federal Rules of Civil Procedure provides that:

In response, Wexford and the Individual Medical Defendants stated that “the ‘computer system’ used by medical staff at the BCDC is owned, possessed and controlled by DPSCS and/or the State of Maryland.” ECF No. 202-1 at 5; see also ECF No. 202-2 at 3–4. Additionally, in response to Plaintiff’s subpoenas served on the State of Maryland, DPSCS, and BCDC, these entities objected to providing native medical records and data, acknowledging that Plaintiff’s request for documents and electronically stored information encompassed such information. ECF No. 207-3 at 3.