Womble objects that the third topic is irrelevant and disproportionate to the needs of the case. Under Federal Rules of Civil Procedure 26 and 30, Vertex may obtain discovery, or testimony, regarding any nonprivileged matter that is relevant to any party's claim or defense. Demonstrating relevance is “not difficult for a party seeking discovery,” Bituminous Cas. Corp. v. Smith Bros. Inc., No. 2:07-CV-354-KS-MTP, 2009 WL 10676928, at *3 (S.D. Miss. Jan. 7, 2009), because “[c]ourts have traditionally construed relevance broadly: information is relevant if it encompasses any matter that bears on, or that reasonably could lead to other matter that could bear on, any issue that is or may be in the case.” Coughlin v. Lee, 446 F.2d 1152, 1159 (5th Cir. 1991) (cleaned up). Furthermore, discovery is not “limited to the merits of a case, for a variety of fact-oriented issues may arise during litigation that are not related to the merits.” Oppenheimer Fund, Inc., 437 U.S. at 351.

*4 That's the gist here. Not only is Womble's representation of Vertex in prior litigation relevant for impeachment purposes, but Vertex seeks disgorgement of any and all legal fees paid to Womble during its breach of the fiduciary relationship and the fiduciary breach of its partner, Charlie Edwards, which Vertex believes occurred between 2006 through present. To date, Womble has never self-reported its nor Edwards' breach in relation to Janice Wolf. According to the Second Restatement of Agency (the same treatise cited by Womble's expert, Benjamin Cooper (Expert Report at 11)), “[a]n agent is entitled to no compensation for conduct which is disobedient, or which is a breach of his duty of loyalty; if such conduct constitutes a willful and deliberate breach of his contract of service, he is not entitled to compensation even for properly performed services for which no compensation is apportioned.” Burrow v. Arce, 997 S.W.2d 229, 237 (1999) (emphasis added) (applying Section 469 the RESTATEMENT (SECOND) OF AGENCY). Moreover, “[t]o limit forfeiture of compensation to instances in which the principal sustains actual damages would conflict with both justifications for the rule. It is the agent's disloyalty, not any resulting harm that violates the fiduciary relationship and thus impairs the basis for compensation. An agent's compensation is not only for specific results but also for loyalty.” Id. at 238. Accordingly, information related to Womble's involvement in litigation on behalf of Vertex is not only highly relevant but needed for impeachment-related purposes and damages sought by Vertex.

This topic seeks highly confidential and proprietary financial information from a privately held law firm, as opposed to a publicly traded company, that is harassing and disproportionate to the claims and any conceivable amount in controversy or legal damages. Except for net worth, the financial information sought is also irrelevant, and only current net worth information would be relevant if/when Vertex were to win a compensatory verdict and proceed to a punitive damages phase of trial. Miss. Code Ann. § 11-1-65 is clear that only Womble's net worth at the time of trial is relevant to punitive damages. Womble has agreed to provide its net worth and the accounting principles applied one month before trial. Applying this Court's balanced approach in Regions Ins., Inc. v. Alliant Ins. Servs., Inc., 2015 WL 1886852 at *3–*7, No. 3:13-CV-667-HTW-LRA (S.D. Miss. Apr. 24, 2015) to this case demonstrates that the provision of a certified statement of net worth in advance of trial is proper and adequate.

*5 To the extent the topic seeks information on financial assets, it is completely disproportionate to the needs of the case and amount in controversy considering Womble has produced a copy of its insurance which provides for $50 million in coverage for this claim. Edwards' handful of communications with Maxey and Wolf in 2006 when Maxey never represented Wolf, Wolf waited 2 years and 4 months to make any EEOC Compliant in 2009 with a completely different lawyer (Watson), and Wolf never filed any lawsuit against Vertex, cannot justify a legal judgment against Womble exceeding $50 million. This is the case even with punitive damages, especially considering Vertex has refused to describe any harm or list any damages after having 15 years to determine if there is any. It would also be burdensome and harassing to require a Womble witness to prepare to provide historical financial information going back 15 years that has no relevance to either the ability to pay a judgment ($50 million in insurance) or to any assessment of punitive damages under the law.

Womble moves to protect the discovery of its finances, net worth, and assets, asserting the information is highly confidential, proprietary, disproportionate to the needs of the case, and burdensome to Womble. It further maintains that the matter constitutes harassment and then pre- judges the case sub judice by alleging that the actions and inactions undergirding Vertex's claims “cannot justify a legal judgment against Womble exceeding” its insurance coverage. Lastly, in an attempt to circumvent the fourth matter, Womble states that it will provide Vertex with its net worth information one month before trial, citing to Mississippi Code Annotated § 11-1-65.

Former and current finances are discoverable at the discovery stage. In fact, the majority of rulings made by magistrate judges and district judges in the Fifth Circuit “allow net worth discovery during the discovery period.” Regions Ins., Inc. v. Alliant Ins. Servs., Inc., No. 3:13-CV-667, 2015 WL 1886852, at *5 (S.D. Miss. Apr. 24, 2015) (collecting cases); accord Mid Continent Cabinetry, Inc. v. George Koch Sons, Inc., 130 F.R.D. 149, 161 (D. Kan. 1990) (“[A] majority of federal courts permit pretrial discovery of financial information of the defendant[.]” (internal quotation marks and citation omitted)). The same is true in Mississippi state courts. E.g., Indep. Life & Accident Ins. Co. v. Peavy, 528 So. 2d 1112, 1117 (Miss. 1988).

Regarding its net worth, Womble seeks to invoke the eight-factor test delineated in Regions Insurance, Inc. to justify its disclosure of net-worth discovery one month before trial. But Regions Insurance, Inc.'s eight-factor test “established a split in this District regarding the discoverability of net worth, [and] it does not constitute controlling law ....” Dear v. Crown Castle S., LLC, No. 3:13-CV-212-WHB-RHW, 2016 WL 7985436, at *7 (S.D. Miss. June 9, 2016). Stalling discovery until one month before trial, as Womble suggests, would unfairly prejudice Vertex's ability to disprove, dispute, or impeach Womble's calculated figures.

As to its financial assets, Womble's categorical contention—that any discovery is inappropriate—holds no water. In Dear, this Court found that the magistrate's ruling that required the defendant to disclose information “regarding its assets, liabilities, and net worth” was “neither clearly erroneous nor contrary to the law.” Id. at *6. Likewise, because the facts of this case date back to 2000 (i.e., the central timeframe is between 2004 and 2012), Vertex needs to depose Womble's designee to adequately assess the value of its claims. This Court should require Womble to disclose relevant discovery related to its net worth and financial assets now, not at the time of trial.

Whether discovery is allowed regarding a private company's net worth, for punitive damages purposes, has been considered by numerous courts with conflicting holdings. The parties' submissions reflect the diverging opinions, and there is law supporting each parties' view.

...

Each side has valid arguments for its position, and the rulings have been inconsistent throughout the courts. A review of the rulings by magistrate judges and district judges throughout the Fifth Circuit reveals that the majority of those opinions allow net worth discovery during the discovery period. See Amin-Akbari v. City of Austin, Texas, et al, Civil Action No. A-13cv472, 2014 U.S. Dist. LEXIS 129119, 2014 WL 4657491 (W.D. Tex. Sept. 16, 2014), citing Mid Continent Cabinetry, Inc. v. George Koch Sons, Inc., 130 F.R.D. 149, 151 (D. Kan. 1990) (when punitive damages claim asserted “...a majority of federal courts permit ‘pretrial discovery of financial information of the defendant without requiring plaintiff to establish a prima facie case on the issue of punitive damages’ ”); Smith v. Detar Hospital, LLC, No. V-10-83, 2011 U.S. Dist. LEXIS 144003, 2011 WL 6217497, *8 (S.D. Tex., Dec. 14, 2011) (parties may discover defendant's net worth where punitive or exemplary damages may be awarded, reviewing Texas state law as well as federal cases in Texas); Hunter v. Copeland, No. 03-2584, 2004 U.S. Dist. LEXIS 12992, 2004 WL 1562832, *3-4 (E.D. La. July 12, 2004) (distinguishing an Alabama ruling and allowing discovery relevant to punitive damages during discovery period).

...

The undersigned finds that a balancing approach should be utilized regarding net worth discovery, balancing the needs of a plaintiff to prove their entitlement to punitive damages versus the consideration of the sensitive and proprietary nature of a defendant's financial information.... In doing so, the following factors will be considered before allowing net worth discovery during the initial discovery period:

1. The strength of plaintiff's claim for punitive damages. Although the undersigned will not attempt to “pre-judge” a plaintiff's case or its claim for punitive damages, the Court will require that plaintiff set forth in particularity the facts it contends establish a basis for punitive damages, i.e., a prima facie claim. No discovery (during the normal discovery period) will be allowed when there is utterly no factual basis for punitive damages or the claim is clearly frivolous.

2. Whether or not the company is public or private. The concerns for the privacy of a publicly held company are not as significant, as the information requested is normally available. Therefore, a public company should produce, if requested, at least a certified statement of its net worth during discovery and supporting documentation.

3. The burden and expense of the discovery. The undersigned will consider the difficulty and expense regarding net worth discovery and/or other punitive damage discovery. It may be that only a certified net worth statement (by an independent auditor) will be allowed, rather than a multitude of supporting documents. The Court will consider requiring plaintiff to pay costs of production if many documents are to be produced.

*7 4. Whether or not the defendant files a dispositive motion regarding punitive damages. If the defendant intends to file (and files) a motion requesting the district judge to dismiss the claim for punitive damages prior to the end of the discovery period, discovery regarding net worth and punitive damages may be disallowed until a decision is made or delayed until after the normal discovery period.

5. Whether or not the district judge will delay the trial on punitive damages for a period of time following a verdict for compensatory damages. There may be district judges who will continue the trial upon motion of the plaintiff to allow for net worth and punitive damage discovery following a favorable verdict for compensatory damages. If so, the balancing inquiry will weigh in favor of not allowing the discovery until and unless a punitive damage hearing is set.

6. Whether a protective order or “attorneys' eyes only” protective order will allay the privacy concerns of defendant. Particularly when the discovery is by one competitor to another, such as the case herein, the undersigned will consider requiring an “attorneys' eyes” only protective order.

7. Whether or not the defendant attests to its ability to produce a current certified net worth statement within a short period of time.

8. The relationship of the parties. The Court will be more apt to protect financial information from being produced to competitors.

In this case, the undersigned has utilized this “balancing approach” and finds that Regions is entitled to net worth discovery at this stage.

Womble appears to “only” object to the allegedly improper breadth of the fifth and sixth topics. Womble argues that it need only prepare its designee for “policies or portions of any handbook” that are strictly related to “Edwards' improper actions with respect to writing Maxey on behalf of Wolf.” Stated differently, Womble (intentionally and) improperly attempts to limit the parties' scope of discovery. Recall, Vertex asserts seven claims [sic] against Womble: (1) breach of fiduciary duty of care, (2) breach of fiduciary duty of loyalty, (3) civil conspiracy, (4) unjust enrichment, (5) conversion, (6) negligence, and (7) negligent supervision and training. Fatally, discovery is not “limited to the merits of a case”; rather, “a variety of fact-oriented issues may arise during litigation that are not related to the merits.” Oppenheimer Fund, Inc., 437 U.S. at 351. Because Womble's preparation of its designee on matters related to its own administrative policies, and because such preparation will neither be overburdensome nor prejudicial, absent a compelling reason otherwise, Vertex should be permitted to depose the designee on Womble's entire handbook, and the policies within it.

Womble objects to the relevancy of the ninth topic. The firm asserts that “Edwards billed no hours for his assistance to Wolf in late 2006.” Womble also takes issue with the request's “time frame and scope.” Contrary to Womble's assertions, other attorneys, including Edwards' associates, could have billed time for assisting Wolf under Edwards' direction. What's worse, Edwards could have billed other clients for his time spent helping Vertex's employees develop employment claims against Vertex. Information obtained to date reveals that Edwards' annual billable hours substantially dropped during the instant case's relevant time period. Communications between Edward and Snider evince their plot to have Vertex's (then) General Counsel, Steve Sinquefield, removed based on the allegations of discrimination and/or retaliation by Snider, Wolf and other employees, and then have him replaced with Snider. At bottom, the information requested is germane to Edwards' motivation to breach his fiduciary duties to Vertex by assisting Vertex's employees, i.e., Wolf and Snider.

Womble also disregards the pertinent timeframe in this case, which extends well-beyond “late 2006.” Providing this type of information is a simple task for Womble. Absent a compelling reason, Womble fails to meet its burden to protect such discovery, and the ninth topic is relevant, reasonable, and not overly burdensome.

Womble's objections applicable to all of these topics is that they seek irrelevant information related to Edwards' assistance to Paine Snider (not Wolf)—claims this Court dismissed and the Fifth Circuit affirmed. The Fifth Circuit's holding [Doc #312 at 32] that “[t]he district court did not err in granting summary judgment on statute of limitations grounds on L-3's claims that Edwards provided Paine Snider with legal assistance and that the Womble firm failed to disclose that legal assistance” makes clear that discovery of Edwards' communications to Paine Snider are no longer relevant to the claims in the case. In other words, the topics are over broad and disproportional to the needs of the case considering the only claims that remain must relate to Edwards' assistance to Wolf.

With respect to topics 16, 17, 20, 21, 22, and 24, Womble must also object because all of the communications, knowledge, and information about Wolf, which are of course relevant, involved its General Counsel's office and are protected by the attorney-client privilege and work product doctrine. As reflected in Womble's privilege log, all such communications occurred after Vertex served Womble with two subpoenas and filed its legal malpractice counterclaim against Womble and were therefor in anticipation of litigation.

The topics all seek irrelevant information contrary to this Court's ruling dismissing all claims related to Edwards' assistance to Paine Snider, not Wolf. They are also overbroad and disproportional to the needs of the case because the only claims that remain must relate to Edwards' assistance to Wolf.

Womble must also object on the basis that these topics invade Womble's attorney-client privilege and seek the work product of its General Counsel's office. The investigations, communications, and knowledge the topic seeks were all conducted, made, or gained by Womble's General Counsel's office in anticipation of litigation after Vertex served Womble with two subpoenas and filed its legal malpractice counterclaim against Womble.

For reference, Bill Raper was Womble's General Counsel during the time period specified, Alison Bost was Womble's Assistant General Counsel, and Richard Rainey acted on behalf of the General Counsel's office with respect to firm employment issues, such as those taken with respect to Edwards. Communications made by Womble's then Chair, Keith Vaugh, or then partners, Betty Quick and Edwards, are of course protected by attorney-client privilege, especially considering the investigation and communications with respect to Edwards' involvement with Wolf occurred after Vertex filed its counterclaim. Any such written communications are contained on Womble's privilege log.

Womble's objections to these topics are the most surprising. Womble broadly contends that, because the Fifth Circuit dismissed certain claims on appeal, “Womble's discovery of Edwards' communications to Paine Snider are no longer relevant to the claims in the case.”

“Relevancy is broadly construed, and a request for discovery should be considered relevant if there is any possibility that the information sought may be relevant to the claim or defense of any party.” Camoco, LLC v. Leyva, 333 F.R.D. 603, 606 (W.D. Tex. 2019) (cleaned up). To hold Womble liable, Vertex must prove that Womble is vicariously liable for Edwards' actions. A component of vicarious liability is whether the employee deviated or departed from his employment. It follows that Womble's knowledge of Edwards's communications with Snider could lend strength to a finding of vicarious liability, especially considering that Womble took steps to keep its breaches and Edwards' breaches a secret from Vertex.

Even the Fifth Circuit's opinion in this case supports this line of thought. The panel explained that discovery produced by Wolf “cast doubt on her deposition testimony” that she “never discussed her claims or Paine Snider's with Edwards.” Instead, “reasonable minds could differ” that Edwards, Snider, and Womble were heavily involved in Wolf's discriminatory allegations. Womble's knowledge of Edwards' communications with Snider, and timing, are relevant to the instant case.

On an aside, but relevant here, Womble improperly sets forth summary judgment-type arguments in its “Factual & Procedural Background” section of its supporting brief, including citations to Baker Donelson Bearman Caldwell & Berkowitz, P.C. v. Seay and Singleton v. Stegall. Again, Womble seeks to mislead this Court by pre-judging this case in the discovery stage. That said, Vertex firmly counters that those cases are distinguishable and inapposite to the case sub judice; but, at this juncture, Vertex reserves any arguments against Womble related to those cases—to be proffered at the appropriate time (i.e., at the summary-judgment stage).

Notwithstanding, Womble's continuous failure to provide Vertex with information related to its investigation of Edwards' unethical behavior is astounding. While Womble has stated that it did not become aware of Edwards' assistance to Wolf until 2012, a letter written by William Raper, Womble's General Counsel, to the North Carolina Bar in 2012, reveals that an investigation of Edwards' misconduct was conducted by Womble in 2007—four years before any litigation began. Had the firm conducted a thorough investigation in 2007, as Raper alleged, Womble would have known then (in 2007) of the unethical assistance and breach of fiduciary duties that its employment practice group leader, Edwards, had provided to Wolf in 2006. Emails, communications, and documents related to Edwards' assistance to Snider could reveal Womble's knowledge of Edwards' assistance to Wolf. Plainly restated, if so, Womble is vicariously liable for Edwards' breaches and perfidious conduct. At the time, Vertex was one of the firm's largest clients. Womble's unwillingness to provide its then-client, Vertex, with its investigative file regarding the actions of one of its partners (and practice chair) in unethically advising Vertex's employees while Womble simultaneously served as outside counsel to Vertex is beyond belief.

*14 Womble has instead decided to play hide-and-seek regarding the findings of its investigation. To this day, Womble has never advised, disclosed, nor produced its findings concerning Edwards' assistance to Wolf. Ironically, while Womble has stated that it did not begin its investigation of Edwards' misconduct until May 2007, after it was alerted to the same by Vertex, its privilege log tells a different story. The privilege log contains an entry dated April 14, 2007 regarding Snider, a month before it was contacted by Vertex. What Womble already knew about Edwards' communications with Vertex's employees before Vertex contacted Womble firm management is critical to Vertex's remaining claims and does not represent any privileges or protections.

Discovery is not a guessing game. Regarding Womble's privileges, protections, and privilege log, Womble again vaguely explains—(first instance) Womble's interrogatory responses; (second instance) Womble's supplemented responses to its inadequate interrogatory responses; (third instance) Allegedly good faith discussions between counsel; (fourth instance) Womble's informal briefing to this Court before the informal discovery hearing; (fifth instance) Womble's oral argument at the informal discovery hearing; and (sixth instance) Instant motion for protective order—why it's asserting the work product doctrine and the attorney-client privilege to protect communications concerning Edwards, Snider, and its internal investigations. See, e.g., Heller v. City of Dallas, 303 F.R.D. 466, 483 (N.D. Tex. 2014) (“So-called boilerplate or unsupported objections—even when asserted in response to a specific discovery request and not as part of a general list of generic objections preceding any response to specific discovery requests—are likewise improper and ineffective and may rise (or fall) to the level of what the Fifth Circuit has described as ‘an all-too-common example’ of the sort of ‘Rambo tactics’ that have brought disrepute upon attorneys and the legal system.’ ” (quoting McLeod, Alexander, Powel & Apffel, P.C. v. Quarles, 894 F.2d 1482, 1484–86 (5th Cir. 1990)).

Womble hinges its blanket privilege-and-protection assertions on the fact that the internal investigations occurred after subpoenas were noticed. It doesn't matter. Any communications discovered between Edwards, Snider, Wolf, and/or Womble attorneys, including administrators, about Edwards's assistance to Snider, Edwards's relationship with Snider, Wolf, and Womble's internal investigations are discoverable. See, e.g., Liberty Mut. Ins. Co. v. Tedford, 644 F. Supp. 2d 753, 764 (N.D. Miss. 2009) (“Where a party puts in issue an attorney's opinion or work product ... both the attorney-client privilege and protections afforded by the work product doctrine are waived.”); Mir v. L-3 Commc'ns Integrated Sys., L.P., 315 F.R.D. 460, 471 (N.D. Tex. 2016) (“More generally, the Fifth Circuit has suggested that waiver may occur where ‘a party has asserted a claim or defense that explicitly relies on the existence or absence of the very communications for which he claims a privilege.’ ” (quoting In re Burlington N., Inc., 822 F.2d 518, 533 (5th Cir. 1987))). Plus, Womble's liability for the professionally deviant acts of Edwards is established by statute. See MISS. CODE ANN. § 79-29-920. Furthermore, just like the privilege-and-protection assertions in its brief, Womble's privilege log fails to include each requisite element of the privilege or protection asserted. See United Investors Life Ins. Co. v. Nationwide Life Ins. Co., 233 F.R.D. 483, 486 (N.D. Miss. 2006) (“Blanket assertions of a privilege are unacceptable ... the court and other parties must be able to test the merits of a privilege claim.”). Perhaps Womble overlooks black letter law. The burden of proving any privileges or protections applicability always rests on the party seeking to shield evidence from disclosure. Fisher v. United States, 425 U.S. 391, 403 (1976); Hickman v. Taylor, 329 U.S. 495, 512 (1947); Hodges, Grant & Kaufmann, 768 F.2d at 722 (work product protection); E.E.O.C., 876 F.3d at 695 (5th Cir. 2017) (attorney-client privilege). Consequently, Womble fails to meet its burden, and its assertions of work product protection and attorney-client privilege must fail. See, e.g., Bess v. Cate, 422 F. App'x 569, 572 (9th Cir. 2011) (finding that “well-established law that parties seeking to invoke privileges are not permitted to provide mere blanket objections to discovery requests” supported a magistrate judge's order to sanction parties who “lodged blanket objections and [thereby] failed to provide sufficient information to enable other parties to evaluate the applicability of the claimed privilege or protection”); Burlington N. & Santa Fe Ry. v. Kapsner, 408 F.3d 1142, 1148 (9th Cir. 2005) (quoting FED. R. CIV. P. 26(b)(5) advisory committee note); MMAR Grp. Inc. v. Dow Jones & Co. Inc., 187 F.R.D. 282, 292 n.6 (S.D. Tex. 1999) (concluding that a party's five general objections, including the attorney-client, work-product, and investigative privileges, were pure boilerplate that impermissibly hampered its opponent's ability to prosecute its own case); Athridge v. Aetna Cas. & Surety Co., 184 F.R.D. 181, 194 (D.D.C. 1998) (finding that assertions of the attorney-client privilege and work-product doctrine were too general to satisfy Rules 33 and 34); Miller v. Pancucci, 141 F.R.D. 292, 302 (C.D. Cal. 1992) (“Objections, in such boilerplate terms as those stated by [d]efendants, are improper and therefore no claim of privilege at all.” (internal quotation marks omitted) (quoting Int'l Paper Co. v. Fireboard Corp., 63 F.R.D. 88, 94 (D. Del. 1974))).

*15 At minimum, before the Rule 30(b)(6) deposition, this Court should conduct an in camera review of all of the documents referenced on Womble's privilege log and conduct a formal inquiry regarding any documents that Womble has failed to even disclose the existence of by not even putting them on the log. Vertex does not believe all germane documents are included on the log. For instance, there is not a single document that is identified as an “investigative report” or an “investigative file” or that in any way appears to outline or disclose the findings of Raper's completed investigation of the issues reported by the General Counsel of L-3 Communications in May 2007. Here, Vertex reported its belief of Edwards' inappropriate conduct with Snider through communications on May 8, 2007. In his letter to the North Carolina Bar, Womble's GC, Raper, stated, “I had completed my initial investigation of the issues reported by the General Counsel of L-3 Communications by mid-May 2007.” However, the privilege log does not include a single entry for mid-May 2007 or any other date in 2007 after May 8, 2007—the day that Vertex contacted Womble regarding Charlie's actions. Where are those documents and why were they not included on the privilege log? Womble contends that it conducted a full-scale investigation but where are the documents evincing that such an investigation occurred? Any thorough investigation conducted by Womble in mid-May 2007 should have revealed the emails located on Womble's server and exchanged in November 2006 between Edwards and Wolf, as well as, other attorneys that Edwards was actively soliciting to represent Wolf against the interest of Womble's and Edwards' client, Vertex.

Additionally, while Womble asserts that it conducted a thorough investigation in mid-May 2007, and that it concluded that “Charlie represented Ms. Snider and Janice Wolf in matters directly adverse to the firm's client , L-3,” Womble failed to report Edwards' actions to the North Carolina bar until July 2012. Why the delay in reporting the findings of a purported 2007 investigation? Information related to Womble's investigation—What documents were reviewed?-Who was interviewed? What did interviewees say at the time? Who reviewed Edwards' emails? and What time period did that review cover?—are all relevant inquiries ripe for discovery in this matter.

(1) the motion for protective order is granted in part and denied in part as to deposition topic no. 3;

(2) the motion for protective order is granted in part and denied in part as to the net worth sub-part of deposition topic no. 4;

(3) the motion for protective order is granted as to the former and current finances and assets sub-part of deposition topic no. 4;

(4) the motion for protective order is denied without prejudice as to Womble's right to seek protection regarding specifically delineated portions of the handbook and administrative policies';

(5) the motion for protective order is granted in part and denied in part as to deposition topic no. 9;

*17 (6) the motion for protective order is held in abeyance as to deposition topic no. 14, 16, 17, 18, 19, 20, 21, 22, and 24;

(7) the motion for protective order is held in abeyance as to deposition topic no. 28, 29, 30, 31, 32, 33, 34, and 35; and

(8) the motion for protective order is denied as to deposition topic no. 38.