Contrary to Womble's position, Vertex has seven outstanding claims remaining in this case: (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. Lawsuits or legal proceedings against Womble, moreover, are relevant to determining whether Womble or its members, partners, or representatives engaged in similar behavior in the past. The third interrogatory also squarely corresponds with Vertex's claim for punitive damages, which requires a showing of, inter alia, past conduct. See Regions Ins., Inc. v. Alliant Ins. Servs., No. 3:13-CV-667-HTW-LRA, 2015 WL 1886852, at *4 (S.D. Miss. Apr. 24, 2015) (“Because a plaintiff must set forth [detailed facts supporting the punitive damages claim] to the factfinder, discovery related to past conduct may lead to admissible evidence.”). Womble should be compelled to supplement its incomplete response to include concerning past lawsuits and legal proceedings.

*3 In this case, as part of the damages sought, 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 upon information and belief Vertex believes occurred between 2006 through present, as Womble has never self-reported as required, its and its Edwards' breach in relation to Janice Wolf. “An 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) (applying Section 469 the Restatement (Second) of Agency). Further, “[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. As such, as a matter of law, information related to Womble's involvement in any civil matter on behalf of Vertex is not only relevant; but unequivocally germane to the damages sought.

Vertex argues it has seven (7) claims (Memo Br. at 10), but they are all based on the one (1) issue that remains in the case as decided by this Court and the Fifth Circuit—Edwards' assistance to Janice Wolf. That issue has been discovered now through the search and production of thousands of emails and the key depositions of Ms. Wolf and her actual EEOC lawyer, Louis Watson. Both testified that Edwards' eight (8) emails had nothing to do with her April 2009 EEOC complaint filed more than two (2) years later without the involvement, input, or referral of John Maxey, the attorney Edwards wrote in November 2006. This interrogatory borders on harassingly overbroad in light of the narrow issue of Edwards' assistance to Wolf and what is already known about it, especially considering Vertex asks for any type of lawsuit in which Womble was a party going back to 2002 (the discovery was propounded and stayed in 2012). While properly objecting to the overbreadth and irrelevancy of lawsuits not involving Edwards' legal malpractice, Womble responded that Edwards has not been involved in any legal malpractice lawsuits prior to this case and that Womble has never declared bankruptcy. Vertex has the only relevant and proportionate answer.

Vertex next makes an argument that irrelevant lawsuits not involving Edwards might somehow be relevant to past conduct, disgorgement damages, and punitive damages. (Memo Br. at 10). These arguments fail when (1) the lone issue is Edwards' assistance to Wolf and (2) Womble provided a response that Edwards was never involved in a legal malpractice suit prior to this one. This answers any relevant question as to past conduct for Edwards which would relate to any claims of negligent supervision or retention of Edwards.7 The legally (and factually) incorrect argument on disgorgement is discussed in detail in section II.C.(3) “Texas Law on Disgorgement Does Not Support Vertex's Discovery” (supra at pp. 10-12).

7. Any negligent retention claim is also unfounded because the lone issue of Edwards' assistance to Wolf occurred in late 2006, and Karelis' call to Womble about Edwards' disloyalty occurred in May 2007. Thus, retention is a non-issue because Edwards' improper actions with respect to writing John Maxey about Wolf were already complete and caused no identifiable harm (even 15 years later). Vertex also elected to continue to hire Womble attorneys in 2008-2010 for other matters despite knowing of Edwards' disloyalty. The negligent retention argument is a nonstarter for this reason, too.

In Interrogatory No. 7, Vertex queries whether any investigations by Womble were conducted concerning Edwards' legal assistance to Snider, Wolf, or any other Vertex employee; and if so, to provide certain information regarding the persons involved or privy to the investigations, including a description of all documents or other evidence received, reviewed, or relied upon by Womble. In response, Womble blanketly invokes the work product doctrine and attorney-client privilege.

Neither the work product doctrine nor the attorney-client privilege protect Womble from disclosing such information. The work product doctrine “protects only the [attorney's work product] and not the underlying facts.” Adams, 973 F.3d at 350. Further, the attorney-client privilege “only protects the disclosure of communications; it does not protect disclosure of the underlying facts by those who communicated with the attorney ....” Dunn v. State Farm Fire & Cas. Co., 122 F.R.D. 507, 509 (N.D. Miss. 1988) (quoting Upjohn Co. v. United States, 449 U.S. 383, 395 (1981)).

These general pillars make sense. For example, the Federal Rules of Civil Procedure and Local Rules of this Court obligate the withholding party to provide the party seeking discovery with alike information in the form of a privilege log. FED. R. CIV. P. 26(b)(5); L.U. RULE 26(e) (“A party withholding information claimed privileged or otherwise protected must submit a privilege log that contains at least the following information: name of the document, electronically stored information, or tangible thing; description of the document, electronically stored information, or tangible thing, which description must include each requisite element of the privilege or protection asserted; date; author(s) recipient(s); and nature of the privilege.” (emphasis added)). District courts in this circuit have also recognized this duty. E.g., Estate of Manship v. United States, 232 F.R.D. 552, 561 (M.D. La. 2005) (“Even if describing the protected materials in a log may difficult to do without revealing the confidential nature of the documents, it is nevertheless the obligation of the [withholding party] under [Federal Rule of Civil Procedure] 26(b)(5).”).

*5 Beyond that, central to Vertex's claims is what Womble knew regarding Edwards' legal assistance to Wolf and Snider and when Womble knew it. A letter from Raper reveals that an investigation of Edwards' misconduct was conducted in 2007—four years before any litigation began. Exhibit “A”; Jarrell, 2019 WL 3400701, at *2 (noting that documents prepared in the ordinary course of business or that would have been created in similar form irrespective of the litigation are not protected as work product); accord Heath v. F/V Zolotoi, 221 F.R.D. 545, 546 (W.D. Wash. 2004) (“More than a mere possibility of litigation must be evidence for materials to be considered immune from discovery under the work-product doctrine.”). Had Womble conducted a thorough investigation in 2007 as Raper alleged, it would have known then (in 2007) of the unethical assistance that its employment practice group leader had provided to Janice Wolf, a Vertex employee, in 2006. At the time, Vertex was one of the firm's largest clients. Womble's unwillingness to provide its client, Vertex, with its investigatory file regarding the actions of one of its partners in unethically advising Vertex's employees while Womble simultaneously served as outside counsel to Vertex is beyond belief. For these reasons, Womble should be compelled to properly respond to Interrogatory No. 7.

Womble appropriately answered the interrogatory by protecting its attorney-client and work product privileges, but by also referring to the documents it has produced. Those significant documents included Bill Raper's emails to Karelis discussing what he did after she called (see Order at 5-6, Doc. # 292), Womble partner Betty Quick's Affidavit, and Raper's letter to the N.C. Bar, in which he describes his actions after both Karelis' call in 2007 and subsequently learning of the emails involving Janice Wolf in 2012. This is made clear in Raper's letter under the headings of “The Events of May 2007” and “2011 and 2012 Developments.” (Mtn. Ex. “A”). There is not an “investigative file” or “report” as Vertex surmises. (Memo Br. at 13). If Vertex does not believe as much, it can depose Raper, who is retired, and ask him. Raper's emails to Karelis and N.C. Bar letter are the best nonprivileged evidence of what was done and when. The only other documents reflecting Womble's General Counsel's investigation into the allegations against Edwards are contained on Womble's Privilege Log. (Ex. “8”). The appropriate invocation of the attorney-client privilege and work product doctrine are evident from the timing and persons involved with the documents listed on Womble's Privilege Log, all of which involved personnel in Womble's General Counsel's office and occurred in anticipation of litigation after either the call from Karelis to Womble complaining about Edwards' conflict of interest on May 7, 2007 or Vertex's subpoenas and eventual lawsuit against Edwards and Womble on February 15, 2012. Regardless, Womble has agreed to have the Court review these documents in camera to confirm its proper application of the privileges and to dispel Vertex's conjecture about what Womble knew about Edwards' assistance to Wolf and when.8

8. One of the first glimpses of Vertex's refusal to accept this Court's rulings dismissing all claims related to Edwards' assistance to Paine Snider is its argument that “... central to Vertex's claims is what Womble knew regarding Edwards' legal assistance to Wolf and Snider and when Womble knew it.” (Memo Br. at 12 (emphasis added)).

Please state, specifically and in detail, each and every communication or conversations that you are aware of involving any partner, administrator and/or agent of Womble Carlyle Sandridge & Rice, LLP, regarding the following:

*6 (a) Any communications that Charles Edwards had with Courtney Paine Snider regarding her employment with L-3;

(b) Any communications that Charles Edwards had with Courtney Paine Snider regarding any potential claims that she may have against L-3;

(c) Any communications that Charles Edwards had with Janice Wolf regarding her employment with L-3;

(d) Any communications that Charles Edwards had with Janice Wolf regarding potential claims that she may have against L-3;

(e) Any communications regarding Steven Sinquefield and Kathleen Karelis; and

(f) Any communications regarding Charles Edwards' and Womble Carlyle's failure to obtain a waiver from L-3 to provide legal advice to Courtney Paine Snider and Janice Wolf.

Please include in your response the date, persons present, and nature or substance of all such communications or conversations. Also, please include any verbatim statements that can be recalled, and state whether or not any such communication or conversation was memorialized in any written or recorded fashion.

Womble objects to this interrogatory to the extent it seeks information concerning claims that have been dismissed. Specifically, Womble objects to subsections (a), (b), and (e) of this interrogatory. Womble further objects to this interrogatory as it exceeds the number permitted by the Court's Case Management Order and Rule 33(a)(1) of the Federal Rules of Civil Procedure, which limits interrogatories to no more than 25 “including all discrete subparts.” Without waiving said objections, Womble responds as follows:

(c) Womble refers Vertex to Charlie Edwards' emails that were previously produced;

(d) Womble refers Vertex to Charlie Edwards' emails that were previously produced; and

(f) Womble refers Verted to Raper's/Bost's Confidential letter to the North Carolina Bar, Quick's Affidavit, and its initial disclosure produced May 28, 2021.

Womble's response to Interrogatory No. 8 incorporates a boilerplate objection. 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)). To Womble, Vertex's interrogatory seeks “information concerning claims that have been dismissed.”

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). Here, Edwards' involvement with Snider is equally relevant to Vertex's claims, as Snider contributed to Edwards' legal assistance to Wolf. See Exhibit “H” (Emails). Recall, Snider was Wolf's direct supervisor, and her best friend. And given the evidence that has come to light, especially the facts relating to Edwards' and Snider's repeated reminders to delete emails to cover their tracks, this Court should find that said responses and document production discoverable. JP Morgan Chase Bank, N.A. v. DataTreasury Corp., 936 F.3d 251, 255 (5th Cir. 2019) (“A trial court enjoys wide discretion in determining the scope and effect of discovery, and it is therefore unusual to find an abuse of discretion in discovery matters.” (citation omitted)).

Womble's limited objections to some portions of this interrogatory are tailored to the rulings of this Court and the Fifth Circuit, specifically the dismissal of all of Vertex's claims “that Edwards provided Paine Snider with legal assistance and that the Womble firm failed to disclose that legal assistance.” (Doc. # 312 at 10). Said another way, Womble's objections adhere to the law of the case. This interrogatory, on the other hand, does not. Subparts (a) and (b) are not about Wolf, but Paine Snider's employment and her claims against Vertex. Subpart (e), when propounded, was focusing on communications about former Vertex in-house counsel, Sinquefield and Karelis, who were concerned about the actions of their fellow in-house counsel, Paine Snider. Vertex knows it propounded this discovery in May 2012, when such requests may have been relevant because it was before this Court's ruling dismissing legal malpractice claims against Paine Snider and those against Edwards and Womble based on Edwards' assistance to Paine-Snider. Now, however, those portions of the request, and Vertex's motion doubling down on them, defy the law of the case. This is also apparent from Vertex's argument that: “Here, Edwards' involvement with Snider is equally relevant to Vertex's claims, as Snider contributed to Edwards's legal assistance to Wolf.” (Memo Br. at 15). Vertex's motion refuses to accept that this Court has already narrowed the scope of discovery by dismissing any claims related to Edwards' legal assistance to Paine Snider and all such claims against Paine-Snider, including with respect to her assistance to Wolf. (Order, Doc. # 292 at 6).9 Vertex's discovery requests and arguments run afoul of the law of the case.

The ninth interrogatory is a formalized request for a privilege log. As discussed, Womble is obligated, without request, pursuant to Federal Rule of Civil Procedure 26(b)(5) and Local Rule 26(e) to provide Vertex with a privilege log describing each document withheld on the bases of privilege or protection. Supra Interrogatory No. 7; Estate of Manship, 232 F.R.D. at 561 (“No exception is made in [Rule 26(b)(5)] for relevant and responsive documents contained in an attorney's legal files.”).

Yet, Womble's answer to Vertex's interrogatory is nonresponsive. Indeed, Womble references that it's withholding documents relating to finances, net worth, and other assets on the bases of relevancy and proportionality.

To that end, 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., 2015 WL 1886852, at *5 (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).

Beyond that, Vertex is seeking actual, incidental, consequential, and punitive damages against Womble, as well as attorneys' fees. It follows that responses and documents regarding Womble's finances, net worth, and asserts are directly relevant to and necessary for Vertex's claim for damages. Consequently, forgoing discovery of Womble's finances until trial, as Womble suggests, unfairly prejudices Vertex's ability to disprove, dispute, or impeach Womble's calculated figures. Womble should be compelled to provide Vertex with its former and current finances, assets, and other during the discovery stage.

*9 Moreover, Womble has withheld several documents, that based on the “general” an “vague” descriptions provided in the privilege log, have absolutely nothing to do with “finances, net worth, and any of its assets. To the contrary, most of the documents withheld appear to go to the heart of two pertinent issues in this case: what did Womble know about Charlie Edwards' legal assistance to Janice Wolf and when did they know it? See Exhibit “E” at Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 26, 27, 28, and 29.

Womble represented to the North Carolina Bar that it conducted a thorough review of Edwards' emails in 2007. Yet, Womble has represented to this Court and in its discovery responses that it did not discover the emails discussing Janice Wolf until 2012 ... why not? The emails regarding Janice Wolf were exchanged and housed on Womble's server in 2006, the year preceding Womble's purported investigation. Whether Womble performed an adequate investigation in 2007 is germane to the remaining claims. It is improper for Womble to attempt to withhold documents that are relevant to showing what it did or perhaps more fitting, failed to do in response to Edwards' misconduct.

For each parcel of real estate in which you own or have an interest, state:

(a) the complete legal description of all such property, including the county and state where located;

(b) what type of percentage of interest you have in any such property;

(c) the present market value of all such property;

(d) the identify of all mortgages, liens and other encumbrances you have on such property, including names, addresses, amounts owed, and dates incurred.

Please identify all checking, savings or money market accounts, certificates of deposit, stocks, bonds, or other securities in which you currently own or have an interest, or which you have owned or had an interest during the last eight (8) years, and for each state:

name and address of the financial institution or entity with which you have such property;

(b) account numbers of each account;

(c) current balance of each checking, savings or money market account and/or certificate of deposit and current value of any stocks, bonds or other securities;

(d) balance of each checking, savings, or money market account and/or certificate of deposit and value of any stocks, bonds, or other securities as of March 2004 and currently.

*10 Similar to the ninth interrogatory, Vertex is seeking actual, incidental, consequential, and punitive damages, as well as attorneys' fees. Thus, documents and information regarding Womble's finances is directly relevant to Vertex's claims for damages. Smith v. Schmidt & McGarland Firm, No. 3:06-CV-25-B-A, 2008 WL 1716646, at *1 (N.D. Miss. Apr. 9, 2008) (“The discovery rules clearly state that discoverable information ‘need not be admissible,’ FED. R. CIV. P. 26(b)(1), and courts have held that financial records, such as a company's net worth, are discoverable ....”). Taking the twelfth and thirteenth interrogatories together, Womble should be compelled to provide supplemented responses and any accompanying documents.

Discovery related to net worth is relevant and necessary for Vertex's claims for damages. “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.” Regions Ins., Inc., 2015 WL 1886852, at *5. Womble therefore should be compelled to provide this information.

Womble provided a Privilege Log listing relevant but privileged documents. (Ex. “8”). Womble has also agreed to have the Court review these documents in camera to confirm its proper application of the privileges and to dispel Vertex's supposition about what Womble knew about Edwards' assistance to Wolf and when. Womble objected to providing information on its assets and finances as irrelevant. The abusive and harassing nature of this discovery is obvious in Interrogatory Nos. 12 & 13 which seek exhaustive information on real estate holdings and historical banking information. As explained in section IV.C. “Abusive Financial Discovery” (supra at p. 15-16), “[u]nder most circumstances, however, a private plaintiff may not discover an opponent's assets until after a judgment against the opponent has been rendered.” Turner, 609 F.2d at 745. With respect net worth, such information is only relevant at the time of trial pursuant to Miss. Code Ann. § 11-1-65. In other words, any historical financial information is irrelevant. More importantly, applying this Court's balanced approach in Regions Ins., 2015WL1886852 at *3-*7, counsels that a certified statement of Womble's net worth in advance of trial is proper and adequate, especially in the face of Vertex's abusive and harassing discovery into a privately-held law firm's assets and finances.

Again, Womble deflects and misconstrues the bones of this case. According to Womble, the sixteenth interrogatory is “irrelevant to the single claim remaining before the Court.” But Vertex asserts seven claims against Vertex, not one. Beyond that, discovery related to attorney billing is relevant. It is pertinent to any post-trail motion for attorneys' fees filed by Vertex.

Vertex has no basis to discover the hourly rates of the undersigned attorneys in this matter, especially at this juncture. If the Court concludes that Vertex is entitled to attorneys' fees, it will then apply the lodestar method to determine the amount to be awarded. Wegner v. Standard Ins. Co., 129 F.3d 814, 822 (5th Cir. 1997). Under this method, the Court will determine the reasonable number of hours expended on the litigation and the reasonable hourly rates for the participating attorneys, and then multiply the two figures together to arrive at the “lodestar.” Id. (citing Louisiana Power & Light Co. v. Kellstrom, 50 F.3d 319, 324 (5th Cir.1995); Forbush v. J.C.Penney Co., 98 F.3d 817, 821 (5th Cir.1996)). “The lodestar is then adjusted upward or downward, depending on the circumstances of the case, after assessing the dozen factors set forth in Johnson v. Georgia Highway Express, 488 F.2d 714, 717–19 (5th Cir.1974). Kellstrom, 50 F.3d at 329; Forbush, 98 F.3d at 821.” Id. In short, hourly rate information is in no way relevant at this stage of the case. If hourly rates become relevant, it is left to the sound discretion of the Court, not Vertex, to determine what the reasonable hourly rate for the participating attorneys will be.

Vertex requested any documents created, prepared, or related to Edwards' removal as a partner from Womble. In return, Womble directed Vertex to a letter by Womble's General Counsel Bill Raper to the North Carolina Bar and Edwards' personnel file. But Edwards' personnel file is devoid of any reasons for Edwards' removal as practice group coordinator. Exhibit “I” (Edwards' Personnel File). Womble's response to Vertex's ninth request for production is incomplete.

To be more specific, Vertex needs to discover any handwritten notes, emails, minutes, or documents that relate to Edwards' removal as partner from Womble. The production of such documents is highly relevant to Vertex's claims because it is obvious that Womble dismissed Edwards as a partner due to his involvement with Vertex's employees, Snider and Wolf. This conclusion is supported by Womble's affirmative response: Womble “requested” Edwards “retirement from the practice of law” “after Edwards' correspondence to John Maxey and Janice Wolf were discovered.” Therefore, Womble should be compelled to produce any and all documents related to Edwards' retirement from Womble under Vertex' ninth request for production.

Womble's responses to Vertex's twelfth, nineteenth, and twentieth requests for productions further illustrate Womble's usage of boilerplate objections. Because such practice is contrary to the spirit of Federal Rule of Civil Procedure 26, Vertex urges this Court to remind Womble's of its duty to produce any and all nonprivileged, unprotected documents, responses, and other discovery related to Vertex's claims against Womble. See Oppenheimer Fund, Inc., 437 U.S. at 351 (“Nor is discovery 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.”). Vertex is hard-pressed not to wonder had Womble complied with its discovery duties and obligations on remand would the parties and this Court be required to resolve the instant discovery disputes on formal motions and a subsequent order.

Identical to Request for Production No. 10, these requests seek discovery contrary to the law of the case—i.e., unrelated to Edwards' assistance to Wolf. Vertex's requests either improperly seek documents related to Edwards' communication, interaction or conduct with Courtney Paine Snider or related to any of the matters referenced in Vertex's counterclaim. A brief review of Vertex's counterclaim (Doc. # 127 at 13-27) shows that the vast majority of it was dismissed by this Court as it related to Paine-Snider. Indeed, only two paragraphs (41 & 42) of the Counterclaim relate to the sole remaining issue of Edwards' assistance to Wolf. Womble's objections are valid. Womble has produced all eight (8) emails that are the universe of documents related to Edwards' assistance to Wolf. (Ex. “2”). Moreover, before all claims related to assistance to Paine-Snider were dismissed by this Court, Womble previously produced 29,066 pages of documents related to that now irrelevant issue.10

10. Vertex improperly asserts that Edwards' emails referenced in Raper's letter were not produced (Memo Br. at 24 n. 2). This is more incorrect speculation. All of Edwards' emails related to Wolf and Paine-Snider and were included in the 29,066 pages of documents produced in response to Vertex's subpoenas in 2011 and 2012.

(1) the motion to compel is granted in part and denied in part as to interrogatory no. 3;

(2) the ruling on Womble's request for a protective order as to interrogatory no. 7 is held in abeyance pending Womble's supplemental privilege log;

(3) the motion to compel is granted as to interrogatory no. 8;

(4) the motion to compel is granted in part and denied in part as to interrogatory no. 9;

(5) the motion to compel is denied as to interrogatory no. 12;

(6) the motion to compel is denied as to interrogatory no. 13;

(7) the motion to compel is granted as to interrogatory no. 14;

(8) the motion to compel is denied as to interrogatory no. 16;

(9) the motion to compel is granted in part and denied in part as to interrogatory no. 19;

(10) the motion to compel is granted as to request for production no. 9;

(11) the motion to compel is granted as to request for production no. 10;

(12) the motion to compel is granted as to request for production no. 12;

(13) the motion to compel is granted as to request for production no. 19;

(14) the motion to compel is granted as to request for production no. 20;