IN RE CONSOLIDATED DISCOVERY IN CASES FILED BY ALYSSON MILLS, IN HER CAPACITY AS RECEIVER FOR ARTHUR LAMAR ADAMS AND MADISON TIMBER PROPERTIES, LLC [Cases consolidated for discovery only: Mills v. Baker Donelson, et al., Civil Action No. 3:18-cv-866-CWR-FKB; Mills v. BankPlus, et al., Civil Action No. 3:19-cv-196-CWR-FKB; Mills v. The UPS Store, Inc., et al., Civil Action No. 3:19-cv-364-CWR-FKB; Mills v. Trustmark, et al., Civil Action No. 3:19-cv-941-CWR-FKB] Arising out of Civil Action No. 3:18-cv-252- CWR-FKB, Securities and Exchange Commission v. Arthur Lamar Adams and Madison Timber Properties, LLC CIVIL ACTION NO.: 3:22-cv-36-CWR-FKB, Civil Action No. 3:18-cv-866-CWR-FKB, Civil Action No. 3:19-cv-196-CWR-FKB, Civil Action No. 3:19-cv-364-CWR-FKB, Civil Action No. 3:19-cv-941-CWR-FKB, Civil Action No. 3:18-cv-252-CWR-FKB United States District Court, S.D. Mississippi, Northern Division Filed March 10, 2023 Counsel Alysson Leigh Mills, Kristen D. Amond, Pro Hac Vice, New Orleans, LA, Brent B. Barriere, Pro Hac Vice, Jeanette A. Donnelly, Pro Hac Vice, Kaja S. Elmer, Pro Hac Vice, Fishman Haygood, LLP, New Orleans, LA, Lilli Evans Bass, Brown Bass & Jeter, PLLC, Jackson, MS, for Alysson Mills. Benjamin W. Graham, Pro Hac Vice, Craig D. Singer, Pro Hac Vice, Hope Elizabeth Daily, Pro Hac Vice, William M. Schmidt, Pro Hac Vice, Williams & Connolly, LLP, Washington, DC, James J. Crongeyer, Jr., Watkins & Eager, PLLC, Jackson, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Baker, Donelson, Bearman, Caldwell & Berkowitz, PC. Cody C. Bailey, R. David Kaufman, Brunini, Grantham, Grower & Hewes, PLLC, Jackson, MS, for Alexander Seawright, LLC, Brent Alexander, Jon Seawright. Alexander N. Breckinridge, V, Pro Hac Vice, Robert B. Bieck, Jr., Pro Hac Vice, Thomas E. Slattery, Pro Hac Vice, Jones Walker, LLP, New Orleans, LA, Kaytie M. Pickett, Jones Walker, LLP, Jackson, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for BankPlus, BankPlus Wealth Management, LLC Laura W. Givens, Robert P. Thompson, McAngus, Goudelock & Courie, LLC, Ridgeland, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Gee Gee Patridge. James W. Newman, IV, Newman & Newman, Ridgeland, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Stewart Patridge. Joseph Miles Forks, Timothy M. Peeples, Wilton V. Byars, III, Daniel, Coker, Horton & Bell, PA, Oxford, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Jason Cowgill. Christopher B. Freeman, Pro Hac Vice, Carlton Fields, PA, Atlanta, GA, Markham R. Leventhal, Steven J. Brodie, Pro Hac Vice, Carlton Fields, PA, Miami, FL, for Federal Insurance Company. John A. Banahan, Bryan, Nelson, Schroeder, Castigliola & Banahan, Pascagoula, MS, for Continental Casualty Company. Adam J. Hunt, Pro Hac Vice, Morrison & Foerster, LLP, New York, NY, LaToya C. Merritt, Mallory K. Bland, Reuben V. Anderson, Phelps Dunbar, LLP, Jackson, MS, Mark R. McDonald, Pro Hac Vice, Morrison & Foerster, LLP, Los Angeles, CA, for The UPS Store, Inc. Randall Scott Wells, William Lee Guice, III, Rushing & Guice, PLLC, Biloxi, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Herring Ventures, LLC, Austin Elsen, Tammie Elsen, Courtney Herring, Diane Lofton, Chandler Westover. G. Todd Burwell, Richard A. Eisenberger, Jr., Burwell Eisenberger, PLLC, Madison, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Rawlings & MacInnis, PA. G. Todd Burwell, Richard A. Eisenberger, Jr., Burwell Eisenberger, PLLC, Madison, MS, for Tammy Vinson, Jeannie Chisholm. J. Collins Wohner, Jr., James M. Tyrone, Paul H. Stephenson, III, Stephanie M. Rippee, William F. Ray, Watkins & Eager, PLLC, Jackson, MS, Robert B. Bieck, Jr.—PHV, Jones Walker, LLP, New Orleans, LA, for Trustmark National Bank. Cody C. Bailey, R. David Kaufman, Jacob A. Bradley, Brunini, Grantham, Grower & Hewes, PLLC, Jackson, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Bennie Butts. Adrienne L. Baker, Pro Hac Vice, Charles T. Coleman, Pro Hac Vice, Wright, Lindsey & Jennings, LLP, Little Rock, AR, Michael Scott Jones, Adams and Reese, LLP, Ridgeland, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Southern Bancorp Bank. Kelly D. Simpkins, Wells Marble & Hurst, PLLC, Jackson, MS, Walter D. Willson, Michael D. Anderson, Wells, Marble & Hurst, PLLC, Ridgeland, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, Robert B. Bieck, Jr.—PHV, Jones Walker, LLP, New Orleans, LA, for Riverhills Bank. Ball, F. Keith, United States Magistrate Judge ORDER *1 This case is before the Court on the Motion to Compel [411] filed by Defendants BankPlus and BankPlus Wealth Management, LLC (collectively “BankPlus”). Alysson Mills, in her capacity as the court-appointed receiver for Arthur Lamar Adams and Madison Timber Properties, LLC (the “Receiver”), filed a response [434] in opposition, and BankPlus filed a reply [456]. Having considered the matter, the Court finds that BankPlus's motion [411] should be granted in part and denied in part. INTRODUCTION In the instant motion, BankPlus moves the Court to enter an order striking the Receiver's general objections to BankPlus's discovery and compelling supplemental responses to Interrogatories Nos. 1-6, 8-10, 13-14, and 17-23 and Requests for Production Nos. 1, 3-4, and 7-25. The parties were unable to resolve their disputes by agreement, and the Court now rules. RECEIVER'S GENERAL OBJECTIONS TO INTERROGATORIES AND REQUESTS FOR PRODUCTION 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. THE COURT'S RULINGS ON INTERROGATORIES In multiple responses to interrogatories, the Receiver stated that “BankPlus is in the best position to know” and that “information the interrogatory seeks is uniquely within BankPlus'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 objects to the interrogatory as “premature.” The Court acknowledges that the Receiver may gain more information responsive to BankPlus's written discovery requests later in the discovery process in this case. But BankPlus is entitled to discover the facts and evidence on which the Receiver bases the Amended Complaint she filed against it, and it is not premature to require the Receiver to disclose that information. The Receiver must respond to BankPlus's interrogatories, based on the information available to her at this time. All of the Receiver's objections to BankPlus's interrogatories as “premature” are hereby overruled. *2 The Receiver also responds to multiple interrogatories by referring to over 100,000 pages of documents. Specifically, she answers interrogatories by referring to BankPlus's records and internal emails [MTR_00347184-MTR_00349327], Lamar Adams's emails [MTR_00124488-MTR_00228823], Wayne Kelly's emails [MTR_00263597-MTR_00294869], and transcripts of S.E.C. depositions of BankPlus employees Gee Gee Patridge, Jason Cowgill, and Martin Murphree [MTR_00354380-MTR_00354519]. See Receiver's Responses to Interrogatory Nos. 10, 20, and 21. In response to other interrogatories, she refers to all of the above-referenced documents, as well as documents with the names and contact information of Madison Timber investors holding promissory notes with amounts due at the time of Madison Timber's collapse [MTR_00353684-MTR_00353690] (“investor identity documents”). See Receiver's Responses to Interrogatory Nos. 13, 14, 17, and 18. And sometimes, she answers interrogatories by referring to over 200,000 pages of documents, specifically referring to all of the above-referenced documents and to every promissory note in her possession that she obtained from any source [MTR_00259538-MTR_00263596; MTR_00000001-MTR_00091813 (records she obtained from the FBI)]. See Receiver's Responses to Interrogatory Nos. 4, 5, 6, and 9 and to Interrogatory Nos. 1, 2, and 3 (which include all of the above, except the investor identity documents). In her responses, the Receiver then states that “[t]he information the interrogatory seeks can be ascertained from those records” and cites to Fed. R. Civ. P. 33(d). However, Fed. R. Civ. P. 33(d)(1) requires a responding party to “specify[ ] the records ... in sufficient detail to enable the interrogating party to locate and identify them as readily as the responding party could.” Regarding the responses to the interrogatories identified above, the Court finds that the Receiver's references to over 100,000 pages of documents lack the requisite specificity under Fed. R. Civ. P. 33(d)(1) and are non-responsive and improper. THE COURT'S RULINGS ON SPECIFIC INTERROGATORIES As to each interrogatory raised in BankPlus's motion, the Court finds and orders as follows: Interrogatory No. 1: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 1. The Court overrules the Receiver's objections that the interrogatory is overbroad, unduly burdensome, vague, ambiguous, and requires speculation. BankPlus is entitled to discover the sales and offers the Receiver claims Stewart Patridge made before the date and time stated in the interrogatory. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 2: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 2. The Court overrules the Receiver's objections that the interrogatory is overbroad, unduly burdensome, vague, ambiguous, and requires speculation. BankPlus is entitled to discover the sales and offers the Receiver claims Martin Murphree made before the date and time stated in the interrogatory. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 3: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 3. The Court overrules the Receiver's objections that the interrogatory is overbroad, unduly burdensome, vague, ambiguous, and requires speculation. BankPlus is entitled to discover the sales and offers the Receiver claims Jason Cowgill made before the date and time stated in the interrogatory. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 4: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 4. The Court overrules the Receiver's objections that the interrogatory is vague and ambiguous. BankPlus is entitled to discover the investors the Receiver claims were introduced to Madison Timber by a BankPlus employee. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 5: BankPlus's motion is granted as to Interrogatory No. 5. The Court overrules the Receiver's objections that the interrogatory is vague and ambiguous. BankPlus is entitled to discover which BankPlus employees the Receiver claims introduced which investors to the subject Ponzi scheme. In response to this interrogatory, the Receiver incorporated her response to Interrogatory No. 4; the Court, therefore, incorporates its ruling on Interrogatory No. 4. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. *3 Interrogatory No. 6: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 6. The Court overrules the Receiver's objections that the interrogatory is vague, ambiguous, overbroad, unduly burdensome, compound, and conjunctive or disjunctive. BankPlus is entitled to discover the Receiver's claims as to when and where its employees introduced investors to the subject Ponzi scheme and a reasonable description of what information the Receiver claims its employees provided those investors. In response to this interrogatory, the Receiver incorporated her response to Interrogatory No. 4; the Court, therefore, incorporates its ruling on Interrogatory No. 4. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 8: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 8. To the extent the interrogatory requests the identity of each investor who is a “net winner,” the motion is denied. According to her response, the Receiver has produced her accounting that she conducted in accordance with her position on the applicable law and her duties, but this interrogatory seeks “net winner” information which the Receiver contends is neither relevant to her claims nor a legally cognizable defense.[1] The Receiver is, however, ordered to supplement her response to identify the investors from whom she has sought to recover funds paid to the investor by the Ponzi scheme in excess of that investor's original investment in the Ponzi scheme. The motion is otherwise denied as to this interrogatory. Interrogatory No. 9: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 9. BankPlus is entitled to discover the identity of the investors for whom the Receiver claims Jason Cowgill deposited checks for Madison Timber into their BankPlus accounts. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. BankPlus states that in her supplemental response, the Receiver identified “two specific Bates-numbered documents” from which “one can determine the identity of two investors – Investor No. 86 and Investor No. 93 (who was also a recruiter).” In her supplemental response ordered herein, the Receiver must specifically list these two investors, if they are responsive to this interrogatory, and must list all other investors responsive to this interrogatory, based on the information available to her at this time. The motion is otherwise denied as to this interrogatory. Interrogatory No. 10: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 10. Although the Receiver's supplemental response identifies some BankPlus employees, she does not state whether those are the only BankPlus employees responsive to this interrogatory and does not provide any responsive information about BankPlus customers or amounts wired. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 13: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 13. Although the Receiver's supplemental response identifies one meeting, she does not state whether it is the only responsive meeting of which she is aware. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 14: BankPlus's motion is denied as to Interrogatory No. 14. The *4 Receiver provided the requested information in her supplemental response. Interrogatory No. 17: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 17. Although the Receiver's supplemental response quotes and cites by Bates number the email quoted in ¶42 of the Amended Complaint and states that the “email identifies the potential investor only as ‘Mr. Jones,’ ” the Receiver does not state whether, based on the information available to her at this time, she can further identify the “potential investor” or state whether the potential investor ever invested in Madison Timber. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 18: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 18. Although the Receiver's supplemental response cites emails by Bates number and states that “[t]hose emails identify the potential investor referenced in ¶43 of [her] Complaint,” the Receiver does not identify the “potential investor” by investor number and does not identify any other investors whose identity is requested in this interrogatory. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 19: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 19. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory, specifically identifying the “client” by investor number and if no investor number has been assigned, by name. The motion is otherwise denied as to this interrogatory. Interrogatory No. 20: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 20. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 21: BankPlus's motion is granted in part and denied in part as to Interrogatory No. 21. In her response to this interrogatory, the Receiver cites documents by Bates number and states that, “throughout 2015 and 2016, and possibly after, Jason Cowgill continued to request the assistance of his former BankPlus colleagues to wire money from BankPlus customers' accounts to Madison Timber, and they obliged.” But the Receiver does not identify any BankPlus employees referenced in ¶57 of her Complaint, as requested in this interrogatory. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 22: BankPlus's motion is denied as to Interrogatory No. 22 on the grounds that it is overbroad. Interrogatory No. 23: BankPlus's motion is denied as to Interrogatory No. 23. THE COURT'S RULINGS ON REQUESTS FOR PRODUCTION In almost all of her responses to BankPlus's requests for production, the Receiver describes (without referencing Bates numbers) over 100,000 pages of documents previously produced by her. Specifically, she refers to the records and internal emails she obtained from BankPlus, transcripts of the S.E.C.'s depositions and/or interviews of BankPlus employees, and Lamar Adams's and Wayne Kelly's emails. See Receiver's Responses to Request for Production Nos. 7, 8, 9, 10, 11, 12, 13, 14, 15, 17, 18, 19, 20, 21, and 23. And in addition to the above-referenced documents, the Receiver refers to emails she obtained from Butler Snow in her response to Request for Production No. 16, to Madison Timber's financial records and bank records from BankPlus, RiverHills Bank, Southern Bancorp, and First National Bank of Clarksdale in her responses to Request for Production Nos. 22 and 24, and to emails she obtained from Randy Shell in her response to Request for Production No. 25. In several of these responses, the Receiver also refers to certain interrogatory responses in which she “pointed to specific Bates ranges of ... documents,” but as to most of those interrogatory responses, the Court has found above that they do not constitute proper answers under Fed. R. Civ. P. 33(d)(1), since they also reference over 100,000 pages of documents.[2] Similarly, the Court finds that all of the Receiver's request for production responses addressed above lack sufficient specificity to comply with Fed. R. Civ. P. 34(b)(2)(E)(i) and are improper. *5 To the extent the Court grants BankPlus's motion on a request for production addressed below, the Court orders and instructs the Receiver 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 those requests, 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 COURT'S RULINGS ON SPECIFIC REQUESTS FOR PRODUCTION As to each request for production raised in BankPlus's motion, the Court finds and orders as follows: Request for Production No. 1: BankPlus's motion is granted in part and denied in part as to Request for Production No. 1. The Court overrules the Receiver's objection that this request seeks information that is irrelevant to the claims and defenses in this case. The Court orders the Receiver to comply with the instructions set forth above, as to this request. The motion is otherwise denied as to this request. Request for Production Nos. 3 and 4: Based on the Court's prior ruling that post-appointment communications between the Receiver and investors are not discoverable, BankPlus's motion is denied as to Request for Production Nos. 3 and 4. See [338] in Mills v. The UPS Store, Inc., et al., Civil Action No. 3:19-cv-364-CWR-FKB. Request for Production Nos. 7-25: BankPlus's motion is granted in part and denied in part as to Request for Production Nos. 7-25. The Court orders the Receiver to comply with the instructions set forth above, as to each of these requests. In complying with the Court's instructions in section (2)(a) above under Fed. R. Civ. P. 34(b)(2)(E)(i), the Receiver must, as to each request, identify the documents on which she relies to support her Amended Complaint allegations in the paragraph specified in the request. The motion is otherwise denied as to these requests. CONCLUSION IT IS, THEREFORE, ORDERED AND ADJUDGED that BankPlus's Motion to Compel [411] is granted in part and denied in part as set forth above and as follows: BankPlus's motion is granted with respect to the Receiver's general objections to BankPlus's interrogatories and requests for production, and they are hereby stricken. BankPlus's motion is granted as to as to Interrogatory Nos. 5. BankPlus's motion is granted in part and denied in part as to Interrogatory Nos. 1, 2, 3, 4, 6, 8, 9, 10, 13, 17, 18, 19, 20, and 21 and Request for Production Nos. 1 and 7-25. BankPlus's motion is denied as to Interrogatory Nos. 14, 22, and 23 and Request for Production Nos. 3 and 4. 5. The Receiver must comply with this Order by April 10, 2023. SO ORDERED on the 10th day of March, 2023. Footnotes [1] To discover the identity of each “net winner” sought in this interrogatory, BankPlus may conduct its own accounting in accordance with its position on the applicable law. [2] Two of the interrogatory responses to which the Receiver refers in her document request responses (specifically, her responses to Interrogatory Nos. 16 and 24) are not the subject of BankPlus's motion, and the Court, therefore, made no findings as to those responses. And another interrogatory response to which she refers (her response to Interrogatory No. 19) does not include references to over 100,000 pages of documents.