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FEARS v. WILHELMINA MODEL AGENCY

United States District Court, S.D. New York


May 4, 2004.

CAROLYN FEARS, et al., Plaintiffs, -against- WILHELMINA MODEL AGENCY, INC., et al., Defendants

The opinion of the court was delivered by: HENRY PITMAN, Magistrate Judge

MEMORANDUM OPINION AND ORDER

By notice of motion dated September 22, 2003 (Docket Item 263), defendants Click Model Management and Next Management Company move for sanctions pursuant to Rules 26, 37(b) and 41(b) of the Federal Rules of Civil Procedure for plaintiffs' failure to properly respond to interrogatories.*fn1 For the reasons stated below, Click's and Next's motion is granted in part and denied in part.

This is an anti-trust case which has been certified as a class action in which plaintiffs allege that defendants have conspired to fix prices in the modeling industry. The allegations and principal defenses are set forth in the Opinion of the Honorable Harold Baer, Jr., United States District Judge, granting in part and denying in part defendants' motion for summary judgment, familiarity with which is assumed. Fears v. Wilhelmina Model Agency, Inc., 02 Civ. 4911 (HB), 2004 WL 594396 (S.D.N.Y. Mar. 23, 2004).

  The current disputes arise out of interrogatories served by Click and Next in the Spring of 2003. Click served its First Set of Interrogatories on the Merits on June 16, 20031 Plaintiffs failed to respond to these interrogatories in a timely manner, and I issued an Order on July 22, 2003 finding that plaintiffs' unjustified failure to respond to the interrogatories in a timely manner resulted in a waiver of all objections and directing plaintiffs to respond to Click's interrogatories no later than July 25, 2003 (Docket Item 188). The deadline was subsequently extended by Judge Baer to July 30, 2003.

  On July 30, 2003, plaintiffs served as interrogatory answers what can best be characterized as an outline of their case. The document served on July 30, 2003 did not, by any stretch of the imagination, constitute answers to Click's specific interrogatories in conformity with Rule 33. Accordingly, on August 14, 2003, I issued a sanction against plaintiffs in the amount of Five Thousand Dollars ($5,000.00) for serving a patently deficient interrogatory response (see Docket Item 198). Subsequent to their July 30, 2003 "answers", but before my August 14, 2003 Order, plaintiffs also served a document entitled "Plaintiffs' Responses to Defendant Click Model Management Inc.'s First Set Of Interrogatories Concerning The Merits", dated August 6, 2003 (Exhibit J to the Affirmation of Olav A. Haazen, Esq., dated October 13, 2003 ("Haazen Aff.")). Plaintiffs' August 6, 2003 interrogatory answers responded to many of Click's interrogatories.

  In addition to their August 6, 2003 interrogatory answers, plaintiffs also served a document entitled "Supplemental Responses To Defendant Click Model Management Inc.'s First Set Of Interrogatories Concerning The Merits", dated September 4, 2003 (Exhibit 2 to the Declaration of Mark W. Moody, Esq., dated September 19, 2003 ("Moody Decl.")). Notwithstanding my Order dated July 22, 2003 which found that all of plaintiffs' objections were waived, plaintiffs' September 4, 2003 supplemental responses asserted objections to many of the interrogatories that plaintiffs had answered in their August 6, 2003 interrogatory answers. In addition, the September 4, 2003 supplemental responses did not indicate on their face whether they were to be considered in conjunction with plaintiffs' August 6, 2003 responses or whether they were intended to substitute for plaintiffs' August 6, 2003 responses. The confusion concerning the status of the September 4, 2003 supplemental responses was compounded by some of the responses themselves. For example, Click's Interrogatory No. 7 sought the identity of individuals knowledgeable concerning the contacts of plaintiffs or their representatives with law enforcement or other governmental agencies with respect to this action or any of the conspiracies or causes of action alleged in the pleadings. In their August 6, 2003 response, plaintiffs idfentified Paul Verquil, Andrew Hayes, Olav Haazen, Christina Lewicky, Jarrod Reich and G. Simone Chafik. In their September 4, 2003 supplemental responses, however, plaintiffs identified only Ms. Chafik. Plaintiffs' September 4, 2003 supplemental responses nowhere explained why the supplemental response contained only a sub-set of the information previously provided in response to this interrogatory.

  Finally, the confusion concerning the relationship between the August 6, 2003 and September 4, 2003 responses was further exacerbated by the fact that plaintiffs' response to the present motion nowhere states that the two sets of responses were intended to be considered in conjunction with each other. Indeed, plaintiffs' written response to the pending motion does not even cite the . . . August 6, 2003 interrogatory responses as containing the information sought. Also at issue in this motion are Click's Third Set of Interrogatories which was served on plaintiffs in mid-July, 2003. In September, 2003, plaintiffs agreed to respond to these interrogatories "without objection" (Moody Decl., Ex. 6), and plaintiffs served responses on or about September 14, 2003 (Moody Decl. Ex. 7).

  The issues concerning Next's interrogatories arise out of a similar record. Next served interrogatories on plaintiffs on or about May 5, 2003 (Exhibit B to the Declaration of Robert J. Tolchin, Esq., dated September 22, 2003 ("Tolchin Decl.")). Plaintiffs served responses on or about June 9, 2003 in which they asserted a number of objections (Tolchin Decl. Ex. C). After conducting a conference on July 7, 2003 during which plaintiffs' responses to Next's interrogatories and other discovery issues were discussed, I entered an Order on July 9, 2003 directing plaintiffs to serve "complete answers to Next's interrogatories 1, 2, 3, 5, 6, 7, 8, 10, 11, 13, 14, 17 and 18 through 36 no later than July 25, 2003" (Docket Item 183; Tolchin Decl., Ex. G at 1-2). Judge Baer subsequently extended the due date for the interrogatory responses to July 31, 2003.

  As was the case with Click's interrogatories, plaintiffs did not serve interrogatory answers on July 31, 2003. Rather, with respect to Next's interrogatories, plaintiffs relied on the same outline that they served in response to Click's interrogatories. On August 6, 2003, plaintiffs served responses to the specific interrogatories identified in my July 9, 2003 Order (Tolchin Decl., Ex. J). Plaintiffs also served supplemental responses to Next's interrogatories on September 4, 2003 (Tolchin Decl., Ex. 0).

  As discussed in more detail below, Click and Next are correct in their contention that plaintiffs have failed to answer sufficiently a substantial number of the interrogatories they had previously been ordered to answer and that sanctions pursuant to Fed.R.Civ.P. 37(b) are appropriate.

 Click's Interrogatories

  Plaintiffs' approach to Click's motion concerning Click's First Set of Interrogatories has caused both Click's counsel and the Court to waste a substantial amount of time for no reason whatsoever. Click's motion was directed to Plaintiffs' September 4, 2003 Supplemental Responses. It was not until oral argument, on April 12, 2004, that plaintiffs first claimed that the interrogatories were answered in their August 6, 2003 responses. Accordingly, the Court wasted time by considering the September 4, 2003 supplemental responses without the benefit of consideration of the August 6, 2003 responses, and Click's counsel was blind-sided by new arguments made for the first time at oral argument. Plaintiffs' counsel has offered no explanation whatsoever for their conduct except to claim that their firm was busy handling other matters and that their response to the motion was not what it should have been. Plaintiffs' omission here is not a trivial one. In a number of instances, plaintiffs' August 6, 2003 responses contain substantive answers to interrogatories that plaintiffs had been ordered to answer (see, e.g., Interrogatory 11). Plaintiffs' September 4, 2003 supplemental responses contain objections to these same interrogatories without any reference to the fact that the interrogatories had been answered a month earlier (see, e.g., Interrogatory 11). This "shell game" response to a discovery motion in which the Court and counsel are compelled to guess as to which discovery response is operative cannot be explained, defended or condoned. I now turn to the specific interrogatory responses to which Click and Next have objected.

 

Plaintiffs' Responses To Click's First Set of Interrogatories
Interrogatory 1. The answer to this interrogatory is sufficient.
  Interrogatories 2, 4, 6 and 10. These interrogatories seek identification of witnesses with knowledge of certain events relevant to the action. Although plaintiffs' responses identify a handful of individuals by name, the responses also refer to other discovery responses in such a manner that the net effect of the response is to identify almost every individual associated with the defendants whose name has been mentioned in the lawsuit or in documents produced by defendants and third parties. Such a response, which cannot possibly be accurate, merely frustrates discovery. Accordingly, no later than May 14, 2004, plaintiffs are directed to serve supplemental responses to these interrogatories which identify by name individuals with knowledge of the facts set forth in each `interrogatory.

  Interrogatory 5.*fn2 Plaintiffs have taken the peculiar course of responding to this interrogatory in their August 6, 2003 responses, but objecting in their September 4, 2003 supplemental responses. Nevertheless, the answers set forth in plaintiffs' August 6, 2003 responses are adequate.

  Interrogatory 7. As noted above, this interrogatory seeks the identification of individuals with knowledge of plaintiffs' or plaintiffs' representatives' contacts with law enforcement or other governmental officials concerning this litigation or any of the conspiracies alleged in this litigation. As also noted above, the August 6, 2003 response identifies six names, while the September 4, 2003 supplemental response identifies only one of those six names. Responding to the interrogatory in this manner is misleading and leaves Click to guess whether the accurate response consists of the six names first provided or the single name subsequently provided. Plaintiffs' counsel has proffered no valid explanation for these inconsistent responses other than an inability to give the interrogatories the attention they deserve due to the press of other business. Plaintiffs are directed to serve an honest and complete response to this interrogatory no later than May 14, 2004.

  Interrogatory 8. This interrogatory seeks identification of documents that identify "the individual or witness in response to Interrogatory #7." Plaintiffs have responded by identifying a sign-in log maintained in the building in which the New York City Department of Consumer Affairs is located. Given the inartful nature of the interrogatory, I conclude, on reflection, that the answer is sufficient. Read literally, the interrogatory could be construed as seeking identification of every document on which the individuals listed in response to Interrogatory 7 are named. Since such a construction would be absurd on its face, I conclude that plaintiffs' response constitutes a good faith attempt to answer the interrogatory.

  Interrogatory 9. The answer to this interrogatory is sufficient.

  Interrogatories 11-14. Interrogatories 11-14 are additional examples of plaintiffs' odd tactic of responding in their August 6, 2003 responses, but objecting in their September 4, 2003 supplemental response. This tactic is all the more bizarre given the fact that I expressly found in my July 22, 2003 Order that all objections were waived. Nevertheless, the answers set forth in plaintiffs' August 6, 2003 response are sufficient.

  Interrogatories 15-18. The answers to these interrogatories are sufficient.

  Interrogatory 19. This interrogatory seeks the identification of witnesses. `The answer needs to be supplemented'with the address and telephone numbers of the individuals identified. Plaintiffs are directed to provide such supplementation no later than May 14, 2004.

 

Plaintiffs' Responses to Click's Third Set of Interrogatories
  Interrogatories 1, 2, 5 and 6. These interrogatories were addressed at the conference held in this matter on April 12, 2004. Plaintiffs were directed at that time to serve supplemental responses by May 3, 2004.

  Interrogatory 3. The answer to this interrogatory is sufficient.

  Interrogatories 4, 6, 14, 16, 18 and 20. These interrogatories seek identification of witnesses with knowledge concerning certain allegations made by plaintiffs, and plaintiffs' responses are designed to obfuscate the information sought rather than to provide it. For example, Interrogatory 3 seeks identification of facts which plaintiffs contend constitute direct evidence of any conspiracy alleged by plaintiffs in the Third Consolidated Amended Complaint, and Interrogatory 4 seeks identification of witnesses with knowledge and documents supportive of the facts identified by plaintiffs in response to Interrogatory 3. Plaintiffs' response to Interrogatory 4 states:

The witnesses with knowledge of the facts relevent to the involvement and participation of defendant Click in the price-fixing conspiracies that form the basis of this action, and the documents supportive of such facts, are identified in the Responses to Interrogatories Nos. 1 and 2 above and in the Responses To Interrogatories No. 1, 16 and 17 of Plaintiffs' Supplemental Click Responses.
The witnesses with knowledge of the facts relevant to, and documents supportive of plaintiffs' allegations concerning, the involvement and participation of each other defendant in the price-fixing conspiracies that form the basis of this action and the documents supportive of such facts, are identified in the following discovery responses: Plaintiffs' Supplemental Responses To Defendant Elite's Contention Interrogatories (-dated September 4, 2003), specifically the supplemental responses to interrogatories 1, 2, 10 and 11; Plaintiffs' Supplemental Responses To Defendant Next's Contention Interrogatories (dated September 4, 2003), specifically the supplemental responses to interrogatories 1, 2, 3, 5, 6, 7, 8, 9, 10, 11, 13, 14, 17, 18, 20, 21, 23, 24, 25, 26, 27, 28, 29, 33 and 34; Plaintiffs' Supplemental Responses To Defendant Wilhelmina's Contention Interrogatories (dated September 12, 2003), specifically the supplemental responses to interrogatories 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20 and 22; Plaintiffs' Supplemental Responses To Defendant MMC's Contention Interrogatories, specifically the supplemental responses to interrogatories 1, 2, 3, 4, 5, 6, 1, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, and 22; Plaintiffs' Supplemental Responses To Defendant Ford Models, Inc.'s Contention Interrogatories (dated September 12, 2003), specifically the supplemental responses to interrogatories 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16,-17, 18, 19, 20, 22, 24, 25, 26, 27, 28 and 31; Plaintiffs' Supplemental Responses To Defendant Q's Contention Interrogatories, specifically the supplemental responses to interrogatories 1, 2, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17 and 19 (dated September 12, 2003).
Plaintiffs' response is deficient in numerous respects. First, plaintiffs did not respond to Interrogatories 1 and 2, but rather promised responses that were never forthcoming. Accordingly, the reference to Responses 1 and 2 are references to nonexistent responses. The second paragraph of the Response is even more troubling, as it requires click to parse through no less than One Hundred Thirteen (113) interrogatory answers in order to derive the responsive information. It is difficult to read the second paragraph of plaintiffs' response and not conclude that the response was drafted to provide the minimum amount of information and to generate the maximum amount of work. Plaintiffs' response does virtually nothing to identify in a meaningful way the witnesses with knowledge of the facts alleged.

  Accordingly, I conclude that plaintiffs' answers to Interrogatories 4, 6, 14, 16, 18 and 20 are insufficient. Plaintiffs are directed to provide supplemental answers by May 14, 2004 identifying witnesses by name.

  Interrogatories 11, 13, 15, 17 and 19. The answers to these interrogatories are sufficient. Next's Contention Interrogatories

  As noted above, plaintiffs were ordered to respond to Next's Interrogatories 1, 2, 3, 5, 6, 1, 8, 10, 11, 13, 14, 17-36 no later than July 25, 2003, which date was subsequently extended to July 31, 2003. Next served responses to these interrogatories on August 6, 2003 and supplemental responses on September 4, 2003.

  In its motion, Next details the deficiencies in each of plaintiffs' August 6, 2003 interrogatory responses, but cites deficiencies in only two of plaintiffs' September 4, 2003 responses. Although I have carefully reviewed Next's analysis of plaintiffs' August 6, 2003 responses and agree that the majority of those responses are deficient, Next's apparent inability to identify similar deficiencies in the September 4, 2003 responses (with two exceptions discussed below) leads me to conclude that Next is satisfied with the September 4, 2003 responses.*fn3 Accord- ingly, with the exception of plaintiffs' responses to Interrogatories 35 and 36, plaintiffs have violated my July 9, 2003 Order by failing to answer these interrogatories in a timely manner but not by failing to provide information (i.e., by July 31, 2003).*fn4

  The only two interrogatories in plaintiffs' September 4, 2003 supplemental responses that Next has identified as being deficient are the responses to Interrogatories 35 and 36. Interrogatory 35 seeks plaintiffs' contention as to what the market commission rate for professional modeling agencies in New York would be in the absence of the conspiracy alleged by plaintiffs and assuming the applicability of General Business Law, Sections 170-90. Interrogatory 36 asks the same question but asks plaintiffs to assume that General Business Law Sections 170-90 are not applicable.*fn5 Although plaintiffs have answered Interrogatory 35, they have not answered Interrogatory 36. Plaintiffs' response nowhere states what plaintiffs believe the commission rate would be in the absence of the alleged conspiracy and assuming the inapplicability of the General Business Law.

 Sanctions

  As the foregoing analysis demonstrates, plaintiffs have unnecessarily made the straight-forward task of responding to interrogatories a difficult and grueling process. I am left with the firm conclusion that plaintiffs' counsel determined they were going to provide discovery in the manner that they saw fit, notwithstanding the requirements of the Federal Rules of Civil Procedure and not withstanding my prior Orders. Such a tactic is, of course, unacceptable and richly deserves the imposition of a sanction.

  Counsel's conduct is particularly disturbing because their failure to respond appropriately to interrogatory answers here is not an isolated event. I have had to sanction plaintiffs' counsel on two prior occasions for discovery shortcomings. Despite these prior sanctions, it appears that plaintiffs' counsel's still unwilling to comply with the Federal Rules of Civil Procedure and my Orders implementing those rules. See generally, McDonald v. Head Criminal Court Supervisor Officer, 850 F.2d 121, 124 (2d Cir. 1988) (party against whom discovery order is issued must either obey the order or obtain stay and pursue appellate remedy).

  Although I believe that a sanction is appropriate, I decline to impose the ultimate sanction of the default judgment sought by Click and Next. As noted by the Honorable David N. Kurd, then Magistrate Judge, now United States District Judge, in Fritter v. Dafina, Inc., 176 F.R.D. 60, 63 (N.D.N.Y. 1997):

The Court may render a default judgment against a party who has failed to fully comply with a discovery order of the court. Fed.R.Civ.P. 37(b)(2)(C). Such a sanction is an extreme measure appropriate only in extreme circumstances. See Bambu Sales Inc. v. Ozak Trading Inc., 58 F.3d 849, 853 (2d Cir. 1995); Woodstock Ventures LC v. Perry, 164 F.R.D. 321, 322 (N.D.N.Y. 1996) (citing Jones v. Niagara Frontier Transp. Auth., 836 F.2d 731, 734 (2d Cir. 1987)). Consequently, the Second Circuit limits default judgments to circumstances "involving willfulness, bad faith, or any fault on the part of the disobedient party." Altschuler v. Samsonite Corp., 109 F.R.D. 353, 356 (E.D.N.Y. 1986) (citing Societe Internationale Pour Participations Industrielles Et Commergiales, S.A. v. Rogers, 357 U.S. 197, 212, 78 S.Ct. 1087, 1095-96, 2 L.Ed.2d 1255 (1958)); see Jones, 836 F.2d at 734. In addition, though, the Second Circuit has held default judgment appropriate where there has been a total dereliction of professional responsibility, evincing circumstances of gross negligence. Cine Forty-Second St. Theatre Corp. v. Allied Artists Pictures Corp., 602 F.2d 1062, 1065-66 (2d Cir. 1979).
Discovery orders are supposed to be followed, and a disobedient party who fails to follow such orders does so at their own peril. Bambu, 58 F.3d at 853 (quoting Update Art, Inc. v. Modiin Publishing, 843 F.2d 67, 73 (2d Cir. 1988)). Default judgments are available "`not merely to penalize . . . but to deter those who might be tempted to such conduct in the absence of such a deterrent.'" Valentine v. Museum of Modern Art, 29 F.3d 47, 50 (2d Cir. 1994)(quoting National Hockey League v. Metropolitan Hockey Club, Inc., 427 U.S. 639, 643, 96 S.Ct. 2778, 2781, 49 L.Ed.2d 747 (1976)). Moreover, severe sanctions such as a default judgment "prevent [s] undue delay[] in the disposition of pending cases and avoid[s] congestion in the court's calendars." Altschuler, 109 F.R.D. at 356 (citing Penthouse Int'l v. Playboy Enterprises, Inc., 663 F.2d 371, 386 (2d Cir. 1981)).
See also National Communications Ass'n, Inc. v. American Tel. & Tel. Co., 92 Civ. 1735 (LAP), 1998 WL 118174 at *3 (S.D.N.Y. Mar. 16, 1998); Sullivan v. City of New York, 94 Civ. 1643 (FB), 1997 WL 642321 at *2 (E.D.N.Y. Sept. 3, 1997); Jeanette Coquette Co. v. Hartford Fire Ins. Co., 93 Civ. 4417 (DAB), 1997 WL 527874 at *l-*2 (S.D.N.Y. Aug. 22, 1997); Edwards v. American Airlines, Inc., 95 Civ. 5356 (SAS), 1996 WL 432472 at *2-*3 (S.D.N.Y. Aug. 1, 1996); Starbrite Waterproofing Co. v. Aim Const. & Contracting Corp., 164 F.R.D. 378, 381-82 (S.D.N.Y. 1996). I conclude that the ultimate sanction of dismissal is not appropriate here because the violations of my prior discovery orders are primarily the result of counsel's conduct and not the result of misconduct on the part of plaintiffs themselves. Although I am aware that there is a long line of authority holding that clients are bound by their counsel's conduct, I cannot ignore the fact that this is a certified class action and that dismissal of all claims against Next and Click would c6nsti-tute an adjudication of the claims of individuals who played no active part in the selection of plaintiffs' counsel. Under these circumstances, I believe that dismissal of the claims against Click and Next would be unduly harsh. Nevertheless, plaintiffs' counsel's repeated failures to comply with discovery orders merits some sanction.

  The factors relevant to determining what sanction, if any, should be imposed include the (1) degree of the offending party's fault, (2) the adequacy of notice and (3) the efficacy of lesser sanctions. See Bambu Sales, Inc. v. Ozak Trading, Inc., 58 F.3d 849, 852 (2d Cir. 1995). As explained below, balancing these three factors supports the imposition of monetary sanctions, but not the sanction of default judgment.

  In this case, counsel's failure to comply with the discovery orders is a matter of fault. The orders in issue were clear and unambiguous, and counsel has offered no valid reason for non-compliance. To the extent counsel relies on the press of other business, the excuse is unconvincing. No attorney can expect an exemption from the requirements of the Federal Rules of Civil Procedure simply because that attorney chooses to take on more work than he or she can handle.

  Second, since Click and Next have proceeded by way of formal motion, plaintiffs have had sufficient notice. See Thomas E. Hoar, Inc. v. Sara Lee Corp., 882 F.2d 682, 688 (2d Cir. 1989); overruled on other grounds, Cunningham v. Hamilton County, 527 U.S. 198 (1999); see also, United States Freight Co. v. Penn Cent. Transp. Co., 716 F.2d 954, 955 (2d Cir. 1983).

  Third, the sanction that I believe is appropriate — a monetary sanction assessed against plaintiffs' counsel — will appropriately punish the party most responsible for the discovery violations without penalizing the plaintiffs themselves. Given the ineffectiveness of my two prior sanction orders, which imposed fines of Two Hundred Fifty Dollars ($250.00) and Five Thousand Dollars ($5,000.00), the sanction appropriate here should be greater.*fn6 For all the foregoing reasons, I conclude that an appropriate sanction in this case is a monetary sanction in the amount of Twenty-Five Thousand Dollars ($25,000.00) to be paid to the Clerk of the Court within ten (10) days of the date of this Order. This sanction shall not be taxed to plaintiffs at the conclusion of this action nor shall it be a taxable cost in the event that plaintiffs prevail. In addition, pursuant to Fed.R.Civ.P. 37(a)(4)(A) & (b)(2), defendants Click and Next are entitled to recover their reasonable attorney's fees in connection with their motion. Counsel are directed to confer and agree on a schedule concerning submissions regarding Click's and Next's attorney's fees. In addition, in the event that plaintiffs prevail in this matter, counsel shall not be permitted to recover attorney's fees for the time spent preparing responses to the interrogatories addressed herein or for the time spent responding to Click's and Next's motions. Finally, plaintiffs are directed to serve complete supplemental responses to the interrogatories identified on Schedule A hereto no later than May 14, 2004, and plaintiffs shall not be permitted to offer at trial information that was called for in Click's and Next's interrogatories, but has not been provided by plaintiffs in the responses they have served to date or in the supplementation ordered herein.

  SO ORDERED [EDITORS' NOTE: THIS PAGE CONTAINED ADDRESSES.] [EDITORS' NOTE: THIS PAGE CONTAINED ADDRESSES.] [EDITORS' NOTE: THIS PAGE CONTAINED ADDRESSES.]

  SCHEDULE A

 Click's First Set of Interrogatories

  2

  4

  6

  7

  10

  19

 Click's Third Set of Interrogatories

  4

  6

  14

  16

  18

  20

 Next's First Set of Interrogatories

  36


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