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., ; Mills v. BankPlus, et al., ; Mills v. The UPS Store, Inc., et al., ; Mills v. Trustmark, et al., ] CIVIL ACTION NO.: 3:22-cv-36-CWR-FKB, Civil Action No. 3:18-cv-252- 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 United States District Court, S.D. Mississippi, Northern Division Filed March 10, 2023 Counsel Jennifer Case, Angela Givens Williams, U.S. Attorney's Office, Jackson, MS, Wm. Shawn Murnahan, Justin M. Delfino, Madison Graham Loomis, U.S. Securities and Exchange Commission - Atlanta Atlanta Regional Office, Atlanta, GA, for Securities and Exchange Commission in No. 3:18-cv-252. John F. Hawkins, Hawkins Law, PC, Jackson, MS, for Birdie Cooperwood, Sherry Russell, William Harry Gibson in No. 3:18-cv-252. Frank W. Trapp, Phelps Dunbar, LLP, Jackson, MS, for William B. McHenry in No. 3:18-cv-252. G. Todd Burwell, Burwell Eisenberger, PLLC, Madison, MS, John L. Davidson, Davidson Bowie, PLLC, Ridgeland, MS, for Jeanne Lehan, Pamela Lehan-Siegel in No. 3:18-cv-252. Douglas Bradley Walsh, Thomas Alan Waller, The Walsh Law Firm, PC, Oxford, MS, David D. O'Donnell, Clayton O'Donnell, PLLC, Oxford, MS, for Gary Property Management LLC in No. 3:18-cv-252. Randall Scott Wells, Rushing & Guice, PLLC, Biloxi, MS, for Herring Ventures, LLC, Austin Elsen, Tammie Elsen, Diane Lofton, Chandler Westover in No. 3:18-cv-252. R. Andrew Taggart, Jr., David Glyn Porter, Taggart, Rimes & Wiggins, PLLC, Ridgeland, MS, for Michael D. Billings, MDB Group, LLC in No. 3:18-cv-252. Craig D. Singer, Pro Hac Vice, Williams & Connolly, LLP, Washington, DC, James J. Crongeyer, Jr., Michael W. Ulmer, Watkins & Eager, PLLC, Jackson, MS, for Baker Donelson Bearman Caldwell & Berkowitz PC in No. 3:18-cv-252. Cody C. Bailey, Brunini, Grantham, Grower & Hewes, PLLC, Jackson, MS, for Alexander Seawright, LLC, Brent Alexander, Jon Seawright in No. 3:18-cv-252. Kelly D. Simpkins, Wells Marble & Hurst, PLLC, Jackson, MS, for Mutual of Omaha Life Insurance Company in No. 3:18-cv-252. Kelly D. Simpkins, Wells Marble & Hurst, PLLC, Jackson, MS, Walter D. Willson, Wells, Marble & Hurst, PLLC, Ridgeland, MS, for Mutual of Omaha Investor Services Inc., Mutual of Omaha Insurance Company in No. 3:18-cv-252. Alan Walter Perry, Simon T. Bailey, Bradley Arant Boult Cummings, LLP, Jackson, MS, for Butler Snow LLP in No. 3:18-cv-252. Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for The UPS Store, Inc. in No. 3:18-cv-252. David Watkins Mockbee, Mockbee Ellis, P.A., Jackson, MS, Douglas T. Miracle, Mississippi Attorney General's Office, Jackson, MS, David B. Ellis, Mockbee, Hall & Drake, PA, Jackson, MS, for C. Delbert Hosemann, Jr. in No. 3:18-cv-252. Alysson Leigh Mills, Kristen D. Amond, Pro Hac Vice, New Orleans, LA, Brent B. Barriere, 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 Leigh Mills in No. 3:18-cv-252. John M. Colette, John M. Colette, PLLC, Jackson, MS, for Arthur Lamar Adams, Madison Timber Properties, LLC in No. 3:18-cv-252. Frank (Kim) C. Breese, III, Breese Law Office, PLLC, Ridgeland, MS, for Alexander Seawright Timber Fund I, LLC in No. 3:18-cv-252. Bradford J. Blackmon, Edward Blackmon, Jr., Blackmon & Blackmon Law Firm, PLLC, Canton, MS, for Butler Snow Advisory Services, LLC, Matt Thornton Blackmon & Blackmon, PLLC in No. 3:18-cv-252. Randall Scott Wells, Rushing & Guice, PLLC, Biloxi, MS, for Courtney Herring in No. 3:18-cv-252. 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 in No. 3:22-cv-36. Thomas R. Hudson, Legal Department, Ridgeland, MS, for Thomas R. Hudson in No. 3:22-cv-36. Ben Thomas Woodhouse, Wilson Elser Moskowitz Edelman & Dicker, LLP, Jackson, MS, for Grace Lott Fuller, CPA in No. 3:22-cv-36. Juanita C. Hernandez, Wm. Smith Greig, Melinda Hardy, U.S. Securities and Exchange Commission, Washington, DC, Wm. Shawn Murnahan, U.S. Securities and Exchange Commission - Atlanta Atlanta Regional Office, Atlanta, GA, for Securities and Exchange Commission in No. 3:22-cv-36. Andrew R. Norwood, U.S. Attorney's Office, Jackson, MS, for Financial Crimes Enforcement Network, United States Postal Inspection Service, United States Secret Service, IRS, Department of Justice in No. 3:22-cv-36. 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 in No. 3:22-cv-36. Cody C. Bailey, R. David Kaufman, Brunini, Grantham, Grower & Hewes, PLLC, Jackson, MS, for Alexander Seawright, LLC, Brent Alexander, Jon Seawright in No. 3:22-cv-36. Alexander N. Breckinridge, V - PHV, Pro Hac Vice, Robert B. Bieck, Jr. - PHV, 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 in No. 3:22-cv-36. 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 in No. 3:22-cv-36. James W. Newman, IV, Newman & Newman, Ridgeland, MS, Mark R. McDonald, Morrison & Foerster, LLP, Los Angeles, CA, for Stewart Patridge in No. 3:22-cv-36. 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 in No. 3:22-cv-36. 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 in No. 3:22-cv-36. John A. Banahan, Bryan, Nelson, Schroeder, Castigliola & Banahan, Pascagoula, MS, for Continental Casualty Company in No. 3:22-cv-36. 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. in No. 3:22-cv-36. 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 in No. 3:22-cv-36. 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 in No. 3:22-cv-36. G. Todd Burwell, Richard A. Eisenberger, Jr., Burwell Eisenberger, PLLC, Madison, MS, for Tammy Vinson, Jeannie Chisholm in No. 3:22-cv-36. 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 in No. 3:22-cv-36. 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 in No. 3:22-cv-36. 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 in No. 3:22-cv-36. 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 in No. 3:22-cv-36. Ball, F. Keith, United States Magistrate Judge ORDER *1 This case is before the Court on the Motion to Compel [417] filed by Defendant Gee Gee Patridge. Joinders in Patridge's motion were filed by Defendants BankPlus, BankPlus Wealth Management, LLC, and Jason Cowgill. See [424] and [430].[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 [449] in opposition, and Patridge filed a reply [467]. Having considered the matter, the Court finds that Patridge's motion [417] to compel should be granted in part and denied in part. INTRODUCTION Gee Gee Patridge propounded to the Receiver twenty-five Interrogatories and thirty-one Requests for Production of Documents. [417] at 2. In the instant motion, Patridge moves the Court to enter an order striking certain objections and statements made by the Receiver in discovery responses and compelling supplemental discovery responses. Patridge takes issue with the Receivers responses to Interrogatory Nos. 1-24 and Request for Production of Documents Nos. 1-27. The parties could not resolve their disputes on these issues, and the Court now rules. THE COURT'S RULINGS ON INTERROGATORIES In multiple responses to interrogatories, the Receiver stated that “Gee Gee Patridge is in the best position to know” and that “information the interrogatory seeks is uniquely within Gee Gee Patridge'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 Gee Gee Patridge's written discovery requests later in the discovery process in this case. But Patridge is entitled to discover the facts and evidence on which the Receiver bases the Amended Complaint she filed against her, and it is not premature to require the Receiver to disclose that information. The Receiver must respond to Patridge's interrogatories, based on the information available to her at this time. All of the Receiver's objections to Patridge's interrogatories as “premature” are hereby overruled. The Receiver also responds to multiple interrogatories by referring to over 100,000 pages of documents. Repeatedly, she answers interrogatories by referring to Gee Gee Patridge's emails [MTR_00347184-MTR_00349327], Lamar Adams's and Wayne Kelly's emails [MTR_0012448-MTR_00228823; MTR_00263597-MTR_00294869], and documents with the names and contact information of all Madison Timber investors holding promissory notes with amounts still due [MTR_00353685-MTR_00353690]. See Receiver's Responses to Interrogatory Nos. 3, 4, 5 (only emails), 6 (only emails), 7, 8 (only emails), 9, 10 (only emails), 11, 12, 13, 14 (only emails), 15, 20 (only emails), 21, 22, and 23. In response to two interrogatories, the Receiver refers to all of the above-referenced emails, as well as the S.E.C. depositions of BankPlus employees (including Gee Gee Patridge, Martin Murphree, and Jason Cowgill) [MTR_00354380-MTR_00354439-MTR_00354519]. See Receiver's Responses to Interrogatory Nos. 16 and 17. And in response to another interrogatory, she refers to all of the above-referenced documents. See Receiver's Responses to Interrogatory No. 18. 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 *2 As to each interrogatory addressed in the motion, the Court finds and orders as follows: Interrogatory No. 1: Patridge's motion is granted as to Interrogatory No. 1. The Receiver is ordered to supplement her response and provide the requested information. Interrogatory No. 2: Patridge's motion is denied without prejudice as to Interrogatory No. 2. The Court finds that at the present stage of this case, the Receiver's response that she “has not made any [such] determination” is sufficient. Interrogatory No. 3: Patridge's motion is granted in part and denied in part as to Interrogatory No. 3. Patridge is entitled to discover the identity of each investor whom the Receiver alleges Patridge recruited, referred, or assisted in recruiting or referring to the Madison Timber Ponzi scheme. The Receiver is ordered to supplement her response to state whether Investor No. 36 is the only investor currently identifiable by the Receiver as responsive to this interrogatory, and if Investor No. 36 is not the only investor currently identifiable by the Receiver as responsive to this interrogatory, the Receiver must identify all such investors. Interrogatory No. 4: Patridge's motion is granted as to Interrogatory No. 4. Patridge is entitled to discover the identity of the requested investors. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. Interrogatory No. 5: Patridge's motion is denied as to Interrogatory No. 5. The Receiver stated her contentions responsive to this interrogatory. Interrogatory No. 6: Patridge's motion is denied as to Interrogatory No. 6. The interrogatory, as constructed, is overly broad. Interrogatory No. 7: Patridge's motion is denied as to Interrogatory No. 7. The Receiver provided the requested information in her supplemental response. Interrogatory No. 8: Patridge's motion is granted in part and denied in part as to Interrogatory No. 8. Patridge is entitled to discover the alleged actions of Gee Gee Patridge on which the Receiver bases her allegation in ¶ 41 of her Amended Complaint that Patridge “continued to facilitate the investments of another investor until Madison Timber's collapse on April 19, 2018” and what the Receiver means by “facilitate,” as requested in the interrogatory. Although the Receiver identified some actions responsive to this interrogatory, she stated that they were “[b]y way of example only.” The Receiver is ordered to supplement her response and provide all such actions of Gee Gee Patridge on which she relies to support her allegation in ¶ 41 of her Amended Complaint and what she means by “facilitate” in that paragraph of her Amended Complaint,. The motion is otherwise denied as to this interrogatory. Interrogatory No. 9: Patridge's motion is granted as to Interrogatory No. 9. Patridge is entitled to discover the identity of the investors for whom the Receiver alleges Patridge served as a “referral contact.” The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. Interrogatory No. 10: Patridge's motion is granted as to Interrogatory No. 10. Patridge is entitled to discover how the Receiver contends Patridge “told [Kelly] she would be ‘glad’ to serve as a ‘referral contact’ for new potential investors,” as the Receiver alleged in ¶ 42 of her Amended Complaint. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. *3 Interrogatory No. 11: Patridge's motion is granted as to Interrogatory No. 11. Patridge is entitled to discover the identity of the “one potential investor” to whom the Receiver refers in ¶ 42 of her Amended Complaint. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. Interrogatory No. 12: Patridge's motion is granted as to Interrogatory No. 12. Patridge is entitled to discover the identity of the investors referenced in ¶ 43 of the Receiver's Amended Complaint. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. Interrogatory No. 13: Patridge's motion is granted as to Interrogatory No. 13. Patridge is entitled to discover the identity of the “particular investor” referenced in ¶ 43 of the Receiver's Amended Complaint. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. Interrogatory No. 14: Patridge's motion is granted as to Interrogatory No. 14. The Receiver is ordered to supplement her response and provide the information requested in this interrogatory. Interrogatory No. 15: Patridge's motion is denied as to Interrogatory No. 15. Considering the specific allegation in the Amended Complaint on which this interrogatory is based, the Receiver provided a sufficient response. Interrogatory No. 16: Patridge's motion is granted in part and denied in part as to Interrogatory No. 16. In her supplemental response, the Receiver identified Jason Cowgill as a BankPlus employee responsive to this interrogatory. The Receiver is ordered to supplement her response to identify all other BankPlus employees to whom she is referring in ¶ 54 of her Amended Complaint. The motion is otherwise denied as to this interrogatory. Interrogatory No. 17: Patridge's motion is granted in part and denied in part as to Interrogatory No. 17. In her supplemental response, the Receiver provided information responsive to this interrogatory, but did not include any dates or amounts as requested. The Receiver is ordered to supplement her response and provide the requested dates and amounts. The motion is otherwise denied as to this interrogatory. Interrogatory No. 18: Patridge's motion is granted in part and denied in part as to Interrogatory No. 18. The Receiver is ordered to supplement her response and state whether she alleges that any particular investors “relied on Gee Gee Patridge when deciding to invest in Madison Timber.” If the Receiver is alleging that any particular investors “relied on Gee Gee Patridge when deciding to invest in Madison Timber,” the Receiver is ordered to further supplement her response and provide the information requested in this interrogatory. The motion is otherwise denied as to this interrogatory. Interrogatory No. 19: Patridge's motion is denied as to Interrogatory No. 19. 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. Further, as worded, there would be no investors responsive to this interrogatory. The interrogatory requests the identity of investors “who independently confirmed that the timber underlying Madison Timber investments was real,” but since it was not real, no such investors would exist. In addition, this interrogatory seeks information from the Receiver on investors' “due diligence” and “good faith,” issues which the Receiver contends are 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. *4 Interrogatory No. 20: Patridge's motion is denied as to Interrogatory No. 20. The interrogatory “calls for the Receiver to speculate” as to others' knowledge, as objected by the Receiver. And as worded, this interrogatory is ambiguous and overly broad in its reference to “other investors.”[2] Interrogatory No. 21: Patridge's motion is denied as to Interrogatory No. 21. The Receiver stated her contentions responsive to this interrogatory. Interrogatory No. 22: Patridge's motion is granted in part and denied in part as to Interrogatory No. 22. The interrogatory is overbroad in its request for “the dates of all ‘visits.’ ” In response to Interrogatory No. 23, the Receiver states that “[t]he investor referenced in the amended complaint's ¶ 72 is Investor No. 36.” [417] at 28. However, the Receiver's response to this interrogatory, which also requests the identity of the investor referenced in ¶ 72 of the Amended Complaint, is equivocal. The Receiver is, therefore, ordered to supplement her response to Interrogatory No. 22 to state that Investor No. 36 is the investor to whom the Receiver refers in ¶ 72 of her Amended Complaint. The motion is otherwise denied as to this interrogatory. Interrogatory No. 23: Patridge's motion is granted as to Interrogatory No. 23. With respect to the Receiver's allegations against Patridge in ¶ 72 of her Amended Complaint, Patridge is entitled to discover the identity of the investor to whom the Receiver refers and what the Receiver contends Gee Gee Patridge did to “facilitate” that investor's investments. Although the Receiver identified the investor as Investor No. 36, she does not disclose anything that she contends Gee Gee Patridge did to facilitate that investor's investments. The Receiver is ordered to supplement her response and provide the information responsive to this interrogatory. Interrogatory No. 24: Patridge's motion is denied as to Interrogatory No. 24. 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. Further, this interrogatory seeks information from the Receiver on investors' “due diligence” and “good faith,” issues which the Receiver contends are 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. THE COURT'S RULINGS ON REQUESTS FOR PRODUCTION In all of her responses to Patridge'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, Lamar Adams's and Wayne Kelly's emails, and the S.E.C. depositions of BankPlus employees, including Gee Gee Patridge, Martin Murphree, and Jason Cowgill in response to each of Patridge's requests, except Request for Production Nos. 20, 21, and 22. In her responses to Request for Production Nos. 20, 21, and 22, she refers to all of the above-referenced documents, except the S.E.C. depositions. The Court finds that all of these responses 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 Patridge'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 addressed in the motion, the Court finds and orders as follows: Request for Production Nos. 1, 2, 3, 4, 6, 8, 9, 10, 11, 12, 15, 16, 17, and 18: Patridge's motion is granted in part and denied in part as to Request for Production Nos. 1, 2, 3, 4, 6, 8, 9, 10, 11, 12, 15, 16, 17, and 18. The Court overrules the Receiver's objections to Request for Production Nos. 10 and 16 as premature, for the reasons stated above in reference to Patridge's interrogatories. 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 responsive documents on which she relies to support her Amended Complaint allegations specified in the request. The motion is otherwise denied as to these requests. Request for Production No. 5: Patridge's motion is granted in part and denied in part as to Request for Production No. 5. The Court orders the Receiver to comply with the instructions set forth above, as to this request. 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 identify the responsive documents on which she relies to support her Amended Complaint allegations against Gee Gee Patridge. The motion is otherwise denied as to this request. Request for Production No. 7: Patridge's motion is granted in part and denied in part as to Request for Production No. 7. The Court orders the Receiver to comply with the instructions set forth above, as to this request. 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 identify the “referral” list referenced in ¶ 44 of her Amended Complaint. The motion is otherwise denied as to this request. Request for Production No. 13: Patridge's motion is granted in part and denied in part as to Request for Production No. 13. The Receiver objected to this request on the grounds that the information sought is irrelevant, stating inter alia that “[i]nvestors' reliance is not an element of any of the Receiver's claims against Gee Gee Patridge.” On Interrogatory No. 18 above, the Court ordered the Receiver to supplement her response and state whether she alleges that any particular investors “relied on Gee Gee Patridge when deciding to invest in Madison Timber.” If the Receiver states in her supplemental response to Interrogatory No. 18 that she is alleging that any particular investor relied upon Gee Gee Patridge, the motion is granted, and the Court orders the Receiver to comply with the instructions set forth above, as to this request. And 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 identify the responsive documents on which she relies to support her allegation that any particular investor relied upon Gee Gee Patridge. The motion is otherwise denied as to this request. *6 Request for Production No. 14: Patridge's motion is denied as to Request for Production No. 14. As worded, this request is ambiguous and overly broad in reference to “other investors.”[3] Request for Production No. 19, 20, 21, and 22: Patridge's motion is granted in part and denied in part as to Request for Production Nos. 19, 20, 21, and 22. The Court overrules the Receiver's objection to Request for Production No. 20 as premature, for the reasons stated above in reference to Patridge's interrogatories. 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 responsive communications on which she relies to support her claims against Gee Gee Patridge. The motion is otherwise denied as to these requests. Request for Production No. 23, 24, 25, 26, and 27: Patridge's motion is granted in part and denied in part as to Request for Production Nos. 23, 24, 25, 26, and 27. The Court overrules the Receiver's objections to these requests as premature, for the reasons stated above in reference to Patridge's interrogatories. 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 responsive documents on which she relies to support or show what is specified in the request. The motion is otherwise denied as to these requests. CONCLUSION IT IS, THEREFORE, ORDERED AND ADJUDGED that Gee Gee Patridge's Motion to Compel [417] is granted in part and denied in part as set forth above and as follows: The motion is granted as to Interrogatory Nos. 1, 4, 9-14, and 23. The motion is granted in part and denied in part as to Interrogatory Nos. 3, 8, 16-18, and 22, and as to Request for Production Nos. 1-13 and 15-27. The motion is denied without prejudice as to Interrogatory No. 2. The motion is denied as to Interrogatory Nos. 5, 6, 7, 15, 19, 20, 21, and 24, and as to Request for Production No. 14. The Receiver must comply with this Order by April 10, 2023. SO ORDERED on the 10th day of March, 2023. Footnotes [1] The last sentence of Defendant Jason Cowgill's joinder states that he “Moves to Compel the Receiver's Responses to his Interrogatories and Requests for Production.” [430] at 3 (emphasis added). In this Order, the Court rules on Defendant Gee Gee Patridge's motion to compel regarding her interrogatories and requests for production. That is the motion in which Cowgill joined. See [430]. If Cowgill wanted a ruling on his interrogatories and requests for production, he should have filed a motion to compel on those specific discovery requests. To the extent Cowgill moves in his joinder to compel responses to his interrogatories and requests for production, his request is not properly before the Court and is, therefore, denied. [2] The Court acknowledges that the Receiver did not object to this interrogatory as ambiguous or overly broad. The Court, however, elects not to enter an order that it would not be able to enforce, due to the ambiguous and overly broad nature of the discovery request. [3] The Court acknowledges that the Receiver did not object to this request as ambiguous or overly broad. The Court, however, elects not to enter an order that it would not be able to enforce, due to the ambiguous and overly broad nature of the discovery request.