*1 This case is before the Court on the Motion to Compel Plaintiff to Answer Discovery [414] filed by Defendant Trustmark National Bank (“Trustmark”). Joinders in Trustmark's motion to compel were filed by BankPlus and BankPlus Wealth Management, LLC [418]; The UPS Store, Inc. [419]; RiverHills Bank [420]; Rawlings & MacInnis, P.A., Tammy Vinson, and Jeannie Chisholm [421]; Herring Ventures, LLC, Austin Elsen, Tammie Elsen, Courtney Herring, Diane Lofton, and Chandler Westover [422]; and Jason Cowgill [431].[1] Alysson Mills, in her capacity as the court-appointed receiver for Arthur Lamar Adams and Madison Timber Properties, LLC (the “Receiver”), filed a response [448] to which Trustmark filed a reply [457]. Having considered the matter, the Court finds that Trustmark's motion [414] should be granted in part and denied in part.

Trustmark propounded to the Receiver a set of Requests for Admission, Interrogatories, and Requests for Production of Documents. In the instant motion, Trustmark moves the Court to enter an order striking the Receiver's general objections to Trustmark's discovery and compelling supplemental responses to Request for Admission Nos. 1-5; Interrogatory Nos. 1-23, 25, 29, and 32-36; and Requests for Production Nos. 1-7, 9, 12-23, 27-29, and 33-37. The parties were unable to reach agreements on these discovery issues, and the Court now rules.

As discussed at the consolidated status conference and motion hearing, objections asserted generally and not in direct response to a specific discovery request do not comply with the Federal Rules of Civil Procedure and are a legal nullity. See [504] at 85; Fed.R.Civ.P. 33(b)(4) (“The grounds for objecting to an interrogatory must be stated with specificity.”); Fed.R.Civ.P. 34(b)(2)(B) and (C) (“For each item or category, the response must either state that [production will be made] as requested or state with specificity the grounds for objecting to the request, including the reasons[,]” and “[a]n objection to part of a request must specify the part and permit [production] of the rest.”); Waters Edge Living, LLC v. RSUI Indem. Co., No. 4:06cv334-RH/WCS, 2008 WL 1816418, at *4 (N.D. Fla. 2008) (“Prefatory general objections that have no narrative connection to a specific discovery request and the specific information sought are a nullity.”); Bailey v. Lockheed Martin Corp., Civil Action No. 4:04-cv-124-LN, 2006 WL 1666275, at *1 (S.D. Miss. June 13, 2006) (acknowledging the requirements of Fed.R.Civ.P. 33(b)(4) and 34(b)(2)(B) and (C) and requiring “self-contained and specific” responses to each discovery request). Accordingly, the Receiver's general objections are hereby stricken.

*2 As to each request for admission raised in Trustmark's motion, the Court finds and orders as follows:

Request for Admission Nos. 1-5: Trustmark's motion is denied as to Request for Admission Nos. 1-5. The Receiver's responses sufficiently comply with Fed. R. Civ. P. 36(a)(4). The Court has considered Trustmark's arguments and authority cited, including Concerned Citizens of Belle Haven v. Belle Haven Club, 223 F.R.D. 39, 44 (D. Conn. 2004), and finds that Rule 36 does not require the Receiver to make the specific inquiries of the United States Attorney's Office or the Federal Bureau of Investigations requested by Trustmark.

In multiple responses to interrogatories, the Receiver stated that “Trustmark is in the best position to know” and that “the information the interrogatory seeks is uniquely within Trustmark's knowledge and ability to ascertain.” The Court finds that those statements are improper and not responsive to the interrogatory propounded.

In response to several interrogatories, the Receiver objected on the grounds that it is “premature.” The Court acknowledges that the Receiver may gain more information responsive to Trustmark's written discovery requests later in the discovery process in this case. But Trustmark is entitled to discover the facts and evidence on which the Receiver bases the Complaint she filed against it, and it is not premature to require the Receiver to disclose that information. The Receiver must respond to Trustmark's interrogatories, based on the information available to her at this time. All of the Receiver's objections to Trustmark's interrogatories as “premature” are hereby overruled.

In response to certain interrogatories, the Receiver incorporated her response(s) to other interrogatories. For example, in response to several interrogatories, the Receiver incorporated her response to Interrogatory No. 1. When the Receiver supplements her responses to comply with this Order, she may certainly include, if responsive to the interrogatory, some or all of the same information provided in another response. But for each interrogatory to which this Order compels a supplemental response, the Receiver must, in her supplemental response and without reference to other responses, provide the information ordered by the Court.

Some of Trustmark's interrogatories seek to require the Receiver to “explain all evidence” or identify all “witness knowledge,” “each and every” fact, act, or omission, or “all” evidence, documents, or witnesses. “[A]n interrogatory may reasonably ask for the material or principal facts which support a contention ... but may be overly broad where it seeks ‘each and every’ single fact upon which a party bases its case[,]” and “[c]ourts have ‘tended toward a middle ground, requiring parties to explain the factual bases for their contentions by providing the material facts upon which they will rely, but not a detailed and exhaustive listing of all of the evidence that will be offered.’ ” In & Out Welders, Inc. v. H & E Equip. Servs., Inc., Civil Action No. 16-86-JWD-RLB, 2018 WL 1370600, at *7 (M.D. La. Mar. 16, 2018) (quoting Linde v. Arab Bank, PLC, No. 04-2799, 2012 WL 957970 (E.D.N.Y. Mar. 21, 2012); see 8B Wright & Miller, Fed. Prac. & Proc. § 2167 (3d ed.) (“Contention interrogatories may be held unduly broad if they ask in an undifferentiated way for ‘all’ facts or witnesses that support an opposing party's case.”). Trustmark is entitled to discover (and the Receiver is required to provide) the Receiver's specific contentions against it and the facts and evidence on which the Receiver bases those contentions. But when appropriate, the Court has ordered the Receiver to provide the “material” facts and evidence, instead of ordering the Receiver to comply with the wording of Trustmark's interrogatory.

*3 As to each interrogatory raised in Trustmark's motion, the Court finds and orders as follows:

Interrogatory No. 1: Trustmark's motion is denied as to Interrogatory No. 1. The interrogatory is overbroad. The Receiver, however, stated her contentions and cited evidence responsive to this interrogatory. Although Trustmark's motion is denied as to this request, the Court notes that the Receiver's references in the last paragraph of her response to over 300,000 pages of documents lack the requisite specificity under Fed. R. Civ. P. 33(d)(1) and are improper.

Interrogatory No. 2: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 2. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. The Receiver is ordered to supplement her response to identify the material evidence on which she bases her assertion that “for years Trustmark suspected that Madison Timber was a Ponzi scheme but did nothing.” The motion is otherwise denied as to this interrogatory.

Interrogatory No. 3: Trustmark's motion is denied as to Interrogatory No. 3. The Receiver stated that the requested information is “not yet known to” her.

Interrogatory No. 4: Trustmark's motion is denied as to Interrogatory No. 4 on the grounds that it is overbroad.

Interrogatory No. 5: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 5. The Receiver is ordered to supplement her response to explain her allegation and identify the material facts on which she relies to support her allegation in ¶ 57 of her Complaint that “Adams' personal financial statements ... grossly inflat[ed] the value of [his] interest in his separate LLCs” and that Trustmark “could see” that, and if the Receiver bases those allegations on evidence not identified in her prior response, identify any such material evidence. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 6: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 6. The Receiver is ordered to supplement her response to identify the material witnesses and documents, which were not identified in her prior response (if any), on which she relies to support her contention that “Trustmark, Butts, and Watkins ... would have known that no independent appraisals would have supported those inflated values,” as alleged in ¶ 57 of her Complaint. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 7: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 7. Although the Receiver provided a substantive response, her answer is nonresponsive to the interrogatory. The Receiver is, therefore, ordered to supplement her response to explain her meaning of “asset-backed investment” as used in her Complaint and to identify the material evidence and information on which she relies to support her allegation that a “13% return” is “better than any return for any other asset-based investment.” The motion is otherwise denied as to this interrogatory.

*4 Interrogatory No. 8: Trustmark's motion is denied as to Interrogatory No. 8. In her response, the Receiver stated her contentions responsive to this interrogatory.

Interrogatory No. 9: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 9. The Court acknowledges that some of the requested information may be the subject of expert testimony to be designated later. But the Receiver is ordered to supplement her response and provide a “yes” or “no” answer, and if the answer is “yes,” information responsive to each sub-part, specifically, (a) an approximate date, if known, (b) the identity of any such agencies and entities, (c) the material facts or information, and (d) any such authorities or standards of care on which the Receiver relies to support her allegation that Trustmark had such a duty or responsibility. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 10: Trustmark's motion is denied as to Interrogatory No. 10. Although the Receiver's reference to over 200,000 pages of documents lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper, the Court finds that the Receiver does not have a duty to inquire of each listed government agency to gather the information requested in this interrogatory and stated that she does not know if or when the listed authorities received any indication of such “suspicious activities.”

Interrogatory No. 11: Trustmark's motion is denied as to Interrogatory No. 11. The Receiver responded that she “does not have the information the interrogatory seeks.” Interrogatory No. 12: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 12. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. Accepting the Receiver's position that the “agreement” on which she bases her civil conspiracy claim against Trustmark may be “express, implied, or based on evidence of a course of conduct,” the Receiver is ordered to supplement her response and identify the agreement (specifying whether express, implied, or based on evidence of a course of conduct) that she contends Trustmark entered with Adams, the unlawful purpose that she contends Trustmark agreed to accomplish with Adams, and the material documents and witnesses on which she relies to support her conspiracy claim against Trustmark. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 13: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 13. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. The Receiver is ordered to supplement her response and identify the material documents and witnesses on which she relies to support her “civil conspiracy” claim against Trustmark, including those indicating that Trustmark was aware of Adams's fraud or wrongful conduct at the time that Trustmark allegedly entered the underlying agreement (if any) that she contends was an element of the conspiracy. The motion is otherwise denied as to this interrogatory.

*5 Interrogatory No. 14: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 14. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. The Receiver is ordered to supplement her response and identify the specific material acts of Trustmark on which she bases the allegation in her Complaint that Trustmark “committed actual fraud.” However, as to the remaining portions of this interrogatory, Trustmark contends that those requests are relevant to the “elements of a fraud claim in Mississippi,” [414-1] at 19, and the Receiver has stated that she “does not allege a fraud claim against Trustmark.” [448] at 32. The motion is, therefore, otherwise denied as to this interrogatory.

Interrogatory No. 15: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 15. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. The Receiver is ordered to supplement her response to identify the material acts by Trustmark on which she relies to support her “aiding and abetting” claim, the material person(s) she contends committed any such acts, and the material evidence on which she relies to support this claim. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 16: Trustmark's motion is denied as to Interrogatory No. 16 on the grounds that it is overbroad.

Interrogatory No. 17: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 17. The Receiver is ordered to supplement her response and provide a “yes” or “no” answer, and if the answer is “yes,” a brief summary of the material details of such interaction, including the names and contact information of material persons involved. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 18: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 18. Trustmark's request, as worded, is overbroad, and the Receiver's references to where these settlements may be found as a matter of public record and in her reports was proper. Trustmark should seek the requested information through a proper request for production of the written settlement agreements, not an interrogatory. However, if the Receiver's settlements with anyone contain terms not included in the public record, her reports, or a written settlement agreement, the Receiver must supplement her response and disclose all such terms and settling parties with whom she agreed to such terms. The Receiver may object to the disclosure of such terms on the grounds of any applicable privilege, protection, or confidentiality, but if withholding any terms, she must state in her supplemental response that she is withholding those terms and identify the settling party with whom the settlement was reached. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 19: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 19. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. The Receiver is ordered to supplement her response and identify the material facts and evidence on which she relies to support her “recklessness, gross negligence, and ... negligence” claims against Trustmark, as well as the standard of care she claims applies, the material acts or omissions by Trustmark that she claims breached that standard, and how she claims such conduct proximately caused any damages sought in this case. The motion is otherwise denied as to this interrogatory.

*6 Interrogatory No. 20: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 20. The Receiver's incorporated reference to over 300,000 pages of documents in Interrogatory No. 1 lacks the requisite specificity under Fed. R. Civ. P. 33(d)(1) and is improper. The Receiver is ordered to supplement her response to identify the material evidence on which she relies to support her “negligent retention and supervision” claim against Trustmark, each Trustmark employee she claims was negligently retained or supervised, the material conduct she contends should have caused Trustmark to supervise the employee differently, the material acts of supervision she claims Trustmark should have performed, and the material reasons she claims a Trustmark employee should have been terminated and approximately when. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 21: Trustmark's motion is denied as to Interrogatory No. 21. The Receiver sufficiently identified the transfers on which she bases her claim.

Interrogatory No. 22: Trustmark's motion is denied as to Interrogatory No. 22. The Receiver sufficiently identified the fees on which she bases her claim.

Interrogatory No. 23: Trustmark's motion is denied as to Interrogatory No. 23. The parties' filings on this motion have not sufficiently informed the Court whether the Receiver has already provided the requested information regarding investors holding outstanding notes as of April 19, 2018 (and if so, in what format) or whether the requested information for all other investors is obtainable and if so, where it is located. Further, this interrogatory seeks a voluminous amount of investor information which the Receiver contends is neither relevant to her claims nor a legally cognizable defense. The scope of investor discovery will be set forth in a subsequent order of this Court, and the discoverability of the requested information (and if discoverable, the appropriate means to discover it) may be addressed at a later date.

Interrogatory No. 25: Trustmark's motion is denied as to Interrogatory No. 25 on the grounds that it is vague, ambiguous, and overbroad.

Interrogatory No. 29: Trustmark's motion is denied as to Interrogatory No. 29 on the grounds that it is overbroad, because it is not in reference to any specific request for production.

Interrogatory No. 32: Trustmark's motion is denied as to Interrogatory No. 32 on the grounds that it is overbroad.

Interrogatory No. 33: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 33. The Receiver is ordered to supplement her response to either (1) confirm that her original response identified all documents she has obtained from the listed agencies; or (2) identify all such documents not identified in her original response and confirm, in her supplemental response, that she has identified all such documents. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 34: Trustmark's motion is granted in part and denied in part as to Interrogatory No. 34. Based on the Court's prior ruling that post-appointment communications between the Receiver and investors are not discoverable, the motion is denied to the extent that it seeks statements from investors to the Receiver. See [338] in Mills v. The UPS Store, Inc., et al., Civil Action No. 3:19-cv-364-CWR-FKB. The Receiver is, however, ordered to supplement her response to either (1) confirm that her original response identified all other statements responsive to this interrogatory; or (2) identify all such statements not identified in her original response and confirm, in her supplemental response, that she has identified all such statements responsive to this interrogatory. The motion is otherwise denied as to this interrogatory.

Interrogatory No. 35: Trustmark's motion is denied as to Interrogatory No. 35. The Court finds the Receiver's response sufficient.

*7 Interrogatory No. 36: Trustmark's motion is denied as to Interrogatory No. 36 on the grounds that it is overbroad.

As to each request for production raised in Trustmark's motion, the Court finds and orders as follows:

Request for Production No. 1: Trustmark's motion is granted in part and denied in part as to Request for Production No. 1. In her response, the Receiver stated that she “has produced all assignments executed by an investor in her favor.” The Receiver is, however, ordered to supplement her response to comply with Fed. R. Civ. P. 34(b)(2)(E)(i) by organizing and labelling (by identifying by Bates number) the documents responsive to this request. The motion is otherwise denied as to this request.

Request for Production No. 2: Based on the Court's prior ruling that post-appointment communications between the Receiver and investors are not discoverable, the motion is denied as to Request for Production No. 2. See [338] in Mills v. The UPS Store, Inc., et al., Civil Action No. 3:19-cv-364-CWR-FKB.

Request for Production No. 3: Trustmark's motion is denied as to Request for Production No. 3 on the grounds that it is overbroad.

Request for Production No. 4: Trustmark's motion is granted in part and denied in part as to Request for Production No. 4. In her response, the Receiver stated that she “has produced ... any promissory notes that [she] obtained from any source” and that she “is not withholding any responsive documents in her possession.” The Receiver is, however, ordered to supplement her response to comply with Fed. R. Civ. P. 34(b)(2)(E)(i) by organizing and labeling (by identifying by Bates number) the documents responsive to this request. The motion is otherwise denied as to this request.

Request for Production No. 5: Trustmark's motion is granted in part and denied in part as to Request for Production No. 5. In her response, the Receiver stated that she “is not withholding any responsive documents in her possession.” The Receiver is, however, ordered to supplement her response to comply with Fed. R. Civ. P. 34(b)(2)(E)(i) by organizing and labeling (by identifying by Bates number) the material documents on which she relies to support her assertion stated in the request. The motion is otherwise denied as to this request.

Request for Production No. 6: Trustmark's motion is granted in part and denied in part as to Request for Production No. 6. To the extent the request seeks “every document and thing ... available to [the Receiver] upon request,” the Court finds that it is overbroad. But as to the request for “every document and thing ... received by” the Receiver from the listed “agencies and authorities,” the Receiver is ordered to: (1) produce all documents responsive to the request which she has not already produced, if any, and to which she does not assert a claim of privilege, protection, or prohibition from disclosure; (2) supplement her response to: (a) organize and label (by identifying by Bates number) the documents responsive to the request, see Fed. R. Civ. P. 34(b)(2)(E)(i); (b) state either that she has produced all responsive documents or that she is withholding from production responsive documents; and (c) if she is withholding responsive documents, state with specificity the grounds for objecting to the request, as to those documents, see Fed. R. Civ. P. 34(b)(2)(B) and (C). The Court also orders that if the Receiver is withholding documents responsive to the request (as limited above), she must produce a privilege log that identifies the responsive documents being withheld and provides the information required by L.U.Civ.R. 26(e). The motion is otherwise denied as to this request.

*8 Request for Production No. 7: Trustmark's motion is denied as to Request for Production No. 7. In her response, the Receiver stated that she “does not have the information the request seeks.”

Request for Production No. 9: Trustmark's motion is denied as to Request for Production No. 9. The Court has ruled that post-appointment communications between the Receiver and investors are not discoverable. See [338] in Mills v. The UPS Store, Inc., et al., Civil Action No. 3:19-cv-364-CWR-FKB.

Request for Production No. 12: Trustmark's motion is denied as to Request for Production No. 12 on the grounds that it is vague, ambiguous, and overbroad. But in her response, the Receiver stated that she “is not withholding any responsive documents in her possession.”

Request for Production No. 13: Trustmark's motion is denied as to Request for Production No. 13 on the grounds that it is overbroad. But in her response, the Receiver stated that she “does not have the information the request seeks” and “is not withholding any responsive documents in her possession.”

Request for Production No. 14: Trustmark's motion is denied as to Request for Production No. 14 on the grounds that it improperly seeks production of public statutes, regulations, learned treatises, and other publications.

Request for Production No. 15: Trustmark's motion is granted in part and denied in part as to Request for Production No. 15. Accepting the Receiver's position that the “agreement” on which she bases her civil conspiracy claim against Trustmark may be “express, implied, or based on evidence of a course of conduct,” the Receiver is ordered, as to this request, to: (1) produce all documents responsive to the request which she has not already produced, if any, and to which she does not assert a claim of privilege, protection, or prohibition from disclosure; (2) supplement her response to: (a) organize and label (by identifying by Bates number) the material documents responsive to the request, see Fed. R. Civ. P. 34(b)(2)(E)(i); (b) state either that she has produced all responsive documents or that she is withholding from production responsive documents; and (c) if she is withholding responsive documents, state with specificity the grounds for objecting to the request, as to those documents, see Fed. R. Civ. P. 34(b)(2)(B) and (C). The Court also orders that if the Receiver is withholding documents responsive to this request, she must produce a privilege log that identifies the responsive documents being withheld and provides the information required by L.U.Civ.R. 26(e). The motion is otherwise denied as to this request.

Request for Production No. 16: Trustmark's motion is denied as to Request for Production No. 16 on the grounds that it is overbroad. But the Receiver stated that she “is not withholding any responsive documents in her possession.”

Request for Production No. 17: Trustmark's motion is denied as to Request for Production No. 17 on the grounds that it is overbroad.

Request for Production No. 18: Trustmark's motion is denied as to Request for Production No. 18 on the grounds that it is overbroad.

Request for Production No. 19: Trustmark's motion is denied as to Request for Production No. 19 on the grounds that it is vague, ambiguous, and overbroad.

*9 Request for Production No. 20: Trustmark's motion is denied as to Request for Production No. 20. The request, as worded, is overbroad.

Request for Production No. 21: Trustmark's motion is granted in part and denied in part as to Request for Production No. 21. The request for “every note, email, letter, or text message ... relating” to any “deals” or “settlements” is overbroad. But as to the request for documents “reflecting” the actual “deals” and “settlements” “entered with anyone [the Receiver] contended was responsible for losses or damages to Madison Timber or Madison Timber investors,” the Receiver is ordered to: (1) produce all documents responsive to the request which she has not already produced, if any, and to which she does not assert a claim of privilege, protection, or prohibition from disclosure; (2) supplement her response to: (a) organize and label (by identifying by Bates number) the documents responsive to the request, see Fed. R. Civ. P. 34(b)(2)(E)(i); (b) state either that she has produced all responsive documents or that she is withholding from production responsive documents; and (c) if she is withholding responsive documents, state with specificity the grounds for objecting to the request, as to those documents, see Fed. R. Civ. P. 34(b)(2)(B) and (C). The Court also orders that if the Receiver is withholding documents responsive to the request (as limited above), she must produce a privilege log that identifies the responsive documents being withheld and provides the information required by L.U.Civ.R. 26(e). The motion is otherwise denied as to this request.

Request for Production No. 22: Trustmark's motion is granted in part and denied in part as to Request for Production No. 22. In her response, the Receiver stated that she “is not withholding any responsive documents in her possession.” The Receiver is, however, ordered to supplement her response to comply with Fed. R. Civ. P. 34(b)(2)(E)(i) by organizing and labeling (by identifying by Bates number) the material documents on which she relies to support her “negligent retention and supervision” claim against Trustmark. The motion is otherwise denied as to this request.

Request for Production No. 23: Trustmark's motion is denied as to Request for Production No. 23 on the grounds that it is overbroad. But in her response, the Receiver stated that she “is not withholding any responsive documents in her possession.”

Request for Production No. 27: Trustmark's motion is granted in part and denied in part as to Request for Production No. 27. The Receiver is ordered, with respect to this request, to: (1) produce all documents responsive to the request which she has not already produced, if any, and to which she does not assert a claim of privilege, protection, or prohibition from disclosure; (2) supplement her response to: (a) organize and label (by identifying by Bates number) the documents responsive to the request, see Fed. R. Civ. P. 34(b)(2)(E)(i); (b) state either that she has produced all responsive documents or that she is withholding from production responsive documents; and (c) if she is withholding responsive documents, state with specificity the grounds for objecting to the request, as to those documents, see Fed. R. Civ. P. 34(b)(2)(B) and (C). The Court also orders that if the Receiver is withholding documents responsive to this request, she must produce a privilege log that identifies the responsive documents being withheld and provides the information required by L.U.Civ.R. 26(e). The motion is otherwise denied as to this request.

*10 Request for Production No. 28: Trustmark's motion is denied as to Request for Production No. 28 on the grounds that it is overbroad.

Request for Production No. 29: Trustmark's motion to compel is granted in part and denied in part as to Request for Production No. 29. In her response, the Receiver stated that she “has produced ... the information the request seeks” and that she “is not withholding any responsive documents in her possession.” The Receiver is, however, ordered to supplement her response to comply with Fed. R. Civ. P. 34(b)(2)(E)(i) by organizing and labeling (by identifying by Bates number) the documents responsive to this request that she has already produced, and if she has updated any of those previously-produced documents since her prior production, she is ordered to produce and identify by Bates number those documents. The motion is otherwise denied as to this request.

Request for Production No. 33: Trustmark's motion is denied as to Request for Production No. 33 on the grounds that it is overbroad. But in her response, the Receiver stated that she “is not withholding any responsive documents in her possession.”

Request for Production No. 34 and 35: Trustmark's motion is denied as to Request for Production Nos. 34 and 35. In her response, the Receiver stated that “[other] than the Receiver's communications with individual investors that are not related to the accounting of the Receiver Estate's damages, [she] is not withholding any responsive documents in her possession.” And the Court has ruled that post-appointment communications between the Receiver and investors are not discoverable. See [338] in Mills v. The UPS Store, Inc., et al., Civil Action No. 3:19-cv-364-CWR-FKB.

Request for Production No. 36: Trustmark's motion is denied as to Request for Production No. 36 on the grounds that it is overbroad. But in her response, the Receiver stated that “[other] than the Receiver's communications with individual investors that are not related to the accounting of the Receiver Estate's damages, [she] is not withholding any responsive documents in her possession.”

Request for Production No. 37: Trustmark's motion is denied as to Request for Production No. 37. This request seeks documents from the Receiver on investors' “due diligence,” an issue which the Receiver contends is neither relevant to her claims nor a legally cognizable defense. The scope of any investor discovery will be set forth in a subsequent order of this Court. But in her response, the Receiver stated that “[other] than the Receiver's communications with individual investors that are not related to the accounting of the Receiver Estate's damages, [she] is not withholding any responsive documents in her possession.”