ALLERGAN, INC., Allergan Pharmaceuticals Ireland Unlimited Company, Allergan USA, Inc., and Allergan Sales, LLC, Plaintiffs, v. REVANCE THERAPEUTICS, INC., Defendant Civil Action No. 3:23-cv-00431 United States District Court, M.D. Tennessee, Nashville Division, NASHVILLE DIVISION Filed March 25, 2025 Presnell, Todd, Special Master ORDER OF THE SPECIAL MASTER RESOLVING THE PARTIES’ FEBRUARY 12, 2025, JOINT SUBMISSION This case comes before the Special Master on the parties’ February 12, 2025, joint submission to the Special Master regarding Revance’s responses to certain discovery and the scheduling of depositions of certain Revance witnesses (the “Submission”).[1] Upon consideration of the parties’ respective positions set forth in the Submission, as well as all of the exhibits submitted in support of the arguments made in that briefing, the Special Master grants in part and denies in part the relief Allergan requests in the Submission. I. General Background This is a trade secrets misappropriation case. Generally, Plaintiffs (various entities doing business under the “Allergan” trade name)[2] allege that Defendant Revance misappropriated trade secrets related to Allergan’s Botox and Juvéderm cosmetic products to aid in Defendant’s development and marketing of its competing products: Daxxify and the RHA Collection. On December 11, 2024, the Court appointed the undersigned as Special Master to aid in resolving discovery disputes that have arisen over the course of this litigation. ECF 292.[3] II. Issues Raised by the Submission Allergan raises several perceived deficiencies in Revance’s responses to certain discovery requests. Specifically, Allergan seeks to compel Revance to (1) respond to Interrogatories 10, 20, 21, 22, 24, and 25; (2) produce documents responsive to numerous Requests for Production[4]; and (3) provide deposition dates for certain witnesses, including Curtis Ruegg, Allen Li, and Connor Gallagher. III. Discussion a. Numerosity of Allergan’s Interrogatories The first issue raised in the Submission relates to whether Allergan has exceeded the 25- interrogatory limit in Fed. R. Civ. P. 33(a)(1). Six interrogatories[5] are at issue: Interrogatory No. 10 Separately for each Asserted Trade Secret, describe the complete factual and legal basis for Your contention, if You so contend, that it is not a trade secret, including but not limited to whether You contend such Asserted Trade Secret is generally known to, and/or readily ascertainable by proper means by, other persons who can obtain economic value from its disclosure or use, and/or Allergan did not maintain reasonable efforts to maintain the confidentiality of, restrict access to, or otherwise protect such Asserted Trade Secret. Interrogatory No. 20 Separately for Daxxify, the Botox Biosimilar, and the RHA Collection, describe in detail the complete factual, evidentiary, and legal bases for Your contention, if You so contend, that Allergan is not entitled to injunctive relief for Revance’s trade secret misappropriation. Interrogatory No. 21 Describe in detail all information that Revance disclosed to any third party regarding the manufacture and process validation and/or characterization for daxibotulinumtoxinA drug substance, including but not limited to Viatris, Shanghai Fosun Pharmaceutical Development Co., Ltd., Shanghai Fosun Pharmaceutical (Group) Co., Sisram Medical, or Sinopharm, by identifying each such third party, specific information and documents disclosed to each third party, the manner in which such information or documents were disclosed to each third party, the persons at Revance involved in each such disclosure, the persons at each third party to whom such information was disclosed, and the reason(s) why such information was disclosed to each third party by Revance. Interrogatory No. 22 Describe in detail the respective roles of Revance, Viatris, and any other third party, in the development, manufacture, FDA regulatory approval process, sales and marketing, and eventual commercial release of the proposed Botox Biosimilar, from the date when development on the proposed Botox Biosimilar began through the present, including any changes to those roles, when those changes occurred, the reasons for those changes, and what interest or involvement Revance has in the Botox Biosimilar since July 11, 2023. Interrogatory No. 24 Describe with particularity any investigation prior to the filing of this litigation that Revance made into the possession, transfer, use, or disclosure of Allergan information by any former Allergan employee, including but not limited to, the individuals listed in the Appendix to Exhibit A of Plaintiffs’ First Set of Requests for Production of Documents and Things to Revance. Interrogatory No. 25 For each response to a Request for Admission served in this litigation that is not an unqualified admission, state the number of the request, and all facts on which you base your response, including identifying all persons with knowledge of those facts and identifying all documents that support your response. Federal Rule of Civil Procedure 33 provides that, “[u]nless otherwise stipulated or ordered by the court, a party may serve on any other party no more than 25 written interrogatories, including all discrete subparts.” Fed. R. Civ. P. 33(a)(1). Rule 33(a)(1) does not define “discrete subparts,” but the Advisory Committee comments note that the rule prevents “the device of joining as ‘subparts’ questions that seek information about discrete separate subjects.” Fed. R Civ. P. 33 Adv. Cmt. Comm. (emphasis added); see Moore v. Mount Zion Baptist Church, No. 3:22-cv-00965, 2023 WL 11944443, at *5 (M.D. Tenn. Sept. 18, 2023). And by way of example, the Advisory Committee stated that “a question asking about communications of a particular type,” i.e., the subject, “should be treated as a single interrogatory even though it requests that the time, place, persons present, and contents be stated separately for each such communication.” Id. A reasonable conclusion from the rule’s language and the committee’s explanation is that a court should count an interrogatory’s subparts as a single interrogatory if those subparts relate to the interrogatory’s primary subject. See, e.g., Greer v. Williams, No. 3:20-cv-00726, 2022 WL 1540411, at *2 (M.D. Tenn. May 16, 2022) (ruling that subparts constituted a single interrogatory because they were “sufficiently related to the main question”); Harhara v. Norville, No. 07-CV-12650, 2007 WL 2897845, at *1 (E.D. Mich. Sept. 25, 2007) (“If the subparts to an interrogatory are necessarily related to the ‘primary question,’ the subparts should be counted as one interrogatory rather than as multiple interrogatories.”). The Sixth Circuit has not identified a “precise formulation” for deciding when subparts relate to the same primary question or subject, Perez v. KDE Equine, LLC, No. 3:15-CV-00562- CRS, 2017 WL 56616, at *3 (W.D. Ky. Jan. 4, 2017), and “[n]umerous courts have grappled with formulating a bright-line test,” Freitag v. La Jolla Bridge, LLC, No. 3:21-CV-01642-LAB-AHG, 2022 WL 2079447, at *3 (S.D. Cal. June 9, 2022). See also Erfindergemeinschaft Uropep GbR v. Eli Lilly & Co., 315 F.R.D. 191, 195 (E.D. Tex. 2016) (“The courts and treatise writers have used different verbal formulations in an effort to fashion a test for whether particular interrogatories contain ‘discrete subparts.’”). As a result, courts within the Sixth Circuit describe the formulation or standard in various ways. Some courts, citing a passage in the Wright & Miller treatise, apply a “common theme” standard, which requires the court to assess whether an interrogatory’s subparts concern a so-called common thread. See, e.g., EEOC v. Supreme Staffing, LLC, No. 2:23-CV02507-SHL-TMP, 2025 WL 725753, at *5 (W.D. Tenn. Mar. 6, 2025) (“If a question focuses on a common theme and subject matter, or if it elicits details concerning a common theme, they are considered to be one question.”); Phoenix Process Equip. Co. v. Cap. Equip. & Trading Corp., No. 3:16CV-00024-RGJ-RSE, 2019 WL 1261352, at *4 (W.D. Ky. Mar. 19, 2019) (citing 8B Charles Alan Wright, Arthur R. Miller & Richard L. Marcus, Fed. Prac. & Proc. § 2168.1, at 39–40 (2010)). This standard has received criticism, however, because “what constitutes ‘a common theme’ is subject to widely divergent views” and “if ‘a common theme’ is broadly interpreted, there could be limitless use of multiple subparts qualifying as a single interrogatory.” Phoenix Process Equip., 2019 WL 1261352, at *4 (citing Eli Lilly & Co., 315 F.R.D. at 196). Most courts, rather, apply a “related question” standard. This standard “states that subparts that are ‘logically or factually subsumed within and necessarily related to the primary question should not be treated as separate interrogatories.’” Phoenix Process Equip., 2019 WL 1261352, at *4 (emphasis added) (quotations omitted). See also Robinson v. Mathis, No. 2:20-cv-02435, 2021 WL 6804133, at *8 (W.D. Tenn. Sept. 14, 2021) (stating that “courts employ the ‘related question’ test when deciding whether subparts are factually or logically related to the principal question”); Moore, 2023 WL 11944443, at *5; Wilkinson v. Greater Dayton Reg’l Transit Auth., No. 3:11cv00247, 2012 WL 3527871 (S.D. Ohio, Aug. 14, 2012) (stating that “interrogatory subparts are to be counted as one interrogatory . . . if they are logically or factually subsumed within and necessarily related to the primary question.”). Stated differently, “‘if the first question can be answered fully and completely without answering the second question,’ then the second question is totally independent of the first and not factually subsumed within it.” Phoenix Process Equip., 2019 WL 1261352, at *4 (quoting Paananen v. Cellco P’ship, No. Co8-1042 RSM, 2009 WL 3327227, at *2 (W.D. Wash. Oct. 8, 2009)). The Special Master finds that the related-question standard represents the better approach because that standard’s inquiry—whether subparts are subsumed within and necessarily related to the primary question—more closely tracks the reasonable conclusion drawn from Rule 33(a)(1)’s language as explained in the Advisory Committee’s comments—that a court should count an interrogatory’s subparts as a single interrogatory if those subparts relate to the interrogatory’s primary subject. And while some decisions from the Middle District use “common thread” language and “related question” language within the same opinion, compare Taylor v. City of Lavergne, Tenn., No. 3:07-0374, 2008 WL 11510398, at *1 (M.D. Tenn. Feb. 15, 2008) (stating that “questions that elicit details concerning a common theme” constitute one interrogatory) with id. (finding that “the subparts of the questions are related to the main question”) (emphasis added), a study of those decisions reveals that “judges in the Middle District of Tennessee have also used the related question test.” Id. See also Moore, 2023 WL 11944443, at *5; Greer, 2022 WL 1540411, at *2. Applying this standard, the Special Master addresses each challenged interrogatory separately below i. Interrogatory No. 10 Revance contends that this Interrogatory, which seeks the “factual and legal basis” for Revance’s contention that each asserted trade secret is not a trade secret, consists of 172 separate questions because it seeks information about Revance’s defense as to each asserted trade secret. Submission at 7. The Special Master disagrees. Interrogatory No. 10 is limited to one subject or primary question—the asserted trade secrets. That there are 172 asserted trade secrets at issue does not mean that Interrogatory No. 10 consists of 172 subparts. Were that the case, Revance’s own Interrogatory No. 1, which asked Allergan to “[d]escribe in detail each trade secret [Allergan] contend[s] Revance misappropriated,” would also exceed the 25-interrogatory limit. See Exhibit A and Exhibit 5 thereto. Accordingly, the Special Master finds that Interrogatory No. 10 consists of just one interrogatory. ii. Interrogatory No. 20 Interrogatory No. 20 seeks information “[s]eparately for Daxxify, the Botox Biosimilar, and the RHA Collection.” Revance contends that Interrogatory No. 20 seeks information about different products and therefore consists of discrete subparts. The Special Master agrees. Interrogatory No. 20 requests information for three distinct products, each of which could be the topic of its own, independent interrogatory. As such, the Special Master finds that Interrogatory No. 20 consists of three subparts. iii. Interrogatories No. 21 and 22 Interrogatories No. 21 and 22 seek information regarding various third parties. Specifically, Interrogatory No. 21 asks Revance to “[d]escribe in detail all information that Revance disclosed to any third party regarding the manufacture and process validation and/or characterization for [Daxxify], including but not limited to Viatris, Shanghai Fosun Pharmaceutical Development Co., Ltd., Shanghai Fosun Pharmaceutical (Group) Co., Sisram Medical, or Sinopharm.” Interrogatory No. 22 asks Revance to “[d]escribe in detail the respective roles of Revance, Viatris, and any other third party, in the development, manufacture, FDA regulatory approval process, sales and marketing, and eventual commercial release of the proposed Botox Biosimilar.” That Allergan listed certain third parties in its Interrogatories serves to tailor the request, not to turn the request into numerous subparts. Interrogatories No. 21 and 22 each focus on a single subject, and the Special Master rejects Revance’s position that, because its response to the Interrogatory will include information for numerous entities that the Interrogatories necessarily consist of multiple subparts. Accordingly, the Special Master finds that Interrogatories No. 21 and 22 each consist of a singular interrogatory. iv. Interrogatory No. 24 Interrogatory No. 24 asks Revance to “[d]escribe with particularity any investigation prior to the filing of this litigation that Revance made into the possession, transfer, use, or disclosure of Allergan information by any former Allergan employee.” Revance states that responding to this Interrogatory will require over 115 separate responses. As with Interrogatories Nos. 21 and 22, the fact that Interrogatory No. 24 seeks information regarding numerous individuals does not mean that it consists of discrete subparts. Interrogatory No. 24 is focused on a common topic—Revance’s investigation into former Allergan employees. Accordingly, the Special Master finds that Interrogatory No. 24 consists of a singular interrogatory. v. Interrogatory No. 25 Interrogatory No. 25 asks that Revance provide a response to each Request for Admission served by Allergan to which Revance did not unqualifiedly admit. Revance denied 19 Requests for Admission. Revance argues that Interrogatory No. 25 consists of 19 discrete subparts. Although it appears that the Sixth Circuit has not addressed this particular issue, Revance cites to caselaw from outside of the Sixth Circuit that indicates “in the context of interrogatories that seek additional information regarding a party’s denial of requests for admission, there is a robust consensus that each request for admission constitutes a discrete subpart and a separate interrogatory.” Superior Sales West, Inc. v. Gonzalez, 335 F.R.D. 98, 104 (W.D. Tex. 2020). At least one court from within the Sixth Circuit has ruled similarly. See Estate of Fahner ex rel Fahner v. Cnty. of Wayne, No. 08-cv-14344, 2009 WL 4644788 at *2 (E.D. Mich., Dec. 3, 2009) (“Plaintiff has effectively turned twenty-seven Requests for Admission into a potential 270 Interrogatories by making an additional ten inquiries for each denied Request for Admission.”). The Special Master agrees that Interrogatory No. 25 constitutes a separate interrogatory for each denied Request for Admission. In sum, the Special Master finds that Interrogatories No. 10, 21, 22, and 24 contain no discrete subparts and orders that Revance must respond to those Interrogatories fully on or before April 7, 2025. The Special Master finds that Interrogatories Nos. 20 and 25 contain discrete subparts. Specifically, Interrogatory No. 20 contains three discrete subparts, and Interrogatory No. 25 contains nineteen discrete subparts, placing Allergan over the presumptive 25-interrogatory limit in Fed. R. Civ. P. 33(a)(1). As a result, the Special Master will not require Revance to respond to current Interrogatories Nos. 20 and 25 and further rules as follows: 1. If Allergan wishes to replace current Interrogatories Nos. 20 and 25 with single interrogatories, it must serve those revised interrogatories on or before March 31, 2025. Revance will have until April 18, 2025, to serve responses to these two new interrogatories. 2. If Allergan wishes to serve more than 25 interrogatories, then it must, on or before April 4, 2025, meet and confer with Revance on the appropriate number. If that meet-and-confer fails to result in a resolution, Allergan may file a motion, in accordance with Local Rule 33.01(b), seeking leave to propound over 25 interrogatories. If Allergan elects to file this motion, it shall do so on or before April 10, 2025. Revance shall file any response on or before April 17, 2025, and Allergan may file a reply brief by April 22, 2025. b. Revance’s document production Allergan next contends that Revance has not fully responded to several Requests for Production. The Requests at issue can be broken into two broad categories: (1) RFP Nos. 71, 72, 78, 79, 81, 82, 83, 85, 86, 89, 90, and 173–179, which seek financial-related information; and (2) RFP Nos. 45, 142–166, 184–186, 196, 197, 200, and 236, which seek product-development information. See Exhibit A and Exhibits 8 and 9 thereto. The Special Master addresses each category in turn. i. RFP Nos. 71, 72, 78, 79, 81, 82, 83, 85, 86, 89, 90, and 173–179 RFP Nos. 71, 72, 78, 79, 81, 82, 83, 85, 86, 89, and 90 seek documents relating to Revance’s profit and loss statements, sales, revenue, costs, and manufacturing information and projections relating to Daxxify and the RHA Collection. See Submission, Exhibit A, at 2 and Exhibit 8 thereto. RFP Nos. 173–179 seek documents relating to the costs associated with the Revance’s research, development, manufacturing, and regulatory approval for Daxxify and its Botox biosimilar. See Submission, Exhibit A, at 2 and Exhibit 9 thereto. According to its Submission, the parties have met and conferred on their disputes relating to these Requests on numerous occasions since July 2024. The Special Master agrees that the information Allergan seeks is relevant to show damages under the Defend Trade Secrets Act, 18 U.S.C. § 1836(b) and the Tennessee Uniform Trade Secrets Act, Tenn. Code Ann. § 47-25-1701 et seq, as each statute allows damages for unjust enrichment caused by a defendant’s misappropriation of a trade secret not otherwise addressed in a plaintiff’s actual loss. See Fed. R. Civ. P. 26(b) (allowing parties to “obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case”). But Allergan’s Submission ignores that Revance has agreed to produce documents responsive to the Requests at issue. See Submission at 8–9. Specifically, according to the Submission, Revance has agreed to search for and produce documents sufficient to show forecast projects, baseline sales data, and publicly available information showing gross sales figures for Daxxify and the RHA Collection in response to RFP Nos. 71 and 72; documents sufficient to show revenues, fixed costs, variable costs, and profits relating to the sale of Daxxify and the RHA Collection in response to RFP Nos. 78 and 81; and documents sufficient to show the amounts of Daxxify and the RHA Collection imported and sold in the United States in response to RFP Nos. 82–90. Id. According to the Submission, Revance has also agreed to produce a territory map showing the assignment of sales representatives in response to RFP No. 79, which seeks “documents sufficient to show current or former geographic territories with respect to the RHA Collection in the United States for any Revance sales representatives who worked for Allergan before joining Revance.” And Revance represents that it will produce documents responsive to RFP Nos. 173–179 within its possession, custody, or control. Submission at 9. The Special Master finds that Revance’s offer to produce certain documents responsive to the Request at issue is a reasonable limitation on otherwise overbroad and far-reaching requests for production. Certain of the Requests at issue seek “all documents” relating to or concerning a certain topic. See, e.g., RFP No. 71 (seeking “[a]ll documents concerning the projected sales of DaxibotulinumtoxinA for Injection in the United States, including, but not limited to, projected profits”). Such requests are overbroad and fail to “describe with reasonable particularity each item or category of items to be inspected.” Fed. R. Civ. P. 34(b)(1)(A). At this stage, Allergan has failed to demonstrate that it is entitled to more far-reaching discovery than that which Revance has offered to produce in response to the Requests at issue. If, after reviewing Revance’s supplemental document production, Allergan believes that it is deficient or that Allergan is entitled to additional documents, it can raise the issue with the Special Master and include more substantive briefing. Consistent with the above, the Special Master denies Allergan’s request to compel Revance to produce documents responsive to RFP Nos. 71, 72, 78, 79, 81, 82, 83, 85, 86, 89, 90, and 173– 179 without prejudice. Revance shall produce documents responsive to those Requests, consistent with its statements set forth in the Submission (and recounted above), no later than April 7, 2025. ii. RFP Nos. 45, 142–166, 184–186, 196, 197, 200, and 236 RFP Nos. 45, 142–166, 184–186, 196, 197, 200, and 236 seek a variety of documents, including, among other things, lab notebooks and development documents for Revance’s Daxxify and RHA Collection products. After reviewing the Parties’ relative position statements on this issue, the Special Master finds that there is no ripe dispute for determination. As an initial matter, much of the Submission concerns Revance’s production of lab notebooks. See Submission at 4–6, 10–12. The Parties have since represented to the Special Master during a telephonic discovery conference held on March 4, 2025, that Revance has completed its rolling production of lab notebooks. Further, Revance represents in the Submission that it “has already agreed to produce documents responsive to many other of Allergan’s RFPs that are the subject of this joint submission.” Submission at 12. Given Revance’s representation that it continues to produce documents responsive to Allergan’s Requests, the Special Master finds that Allergan’s request to compel full responses to its RFPs is premature. Accordingly, the Special Master denies without prejudice Allergan’s request to compel Revance to respond to RFP Nos. 45, 142–166, 184–186, 196, 197, 200, and 236. To the extent it has not done so already, Revance must complete its production of documents responsive to those requests on or before April 7, 2025. c. Depositions of certain Revance witnesses Allergan contends that Revance has repeatedly delayed and cancelled certain depositions of its employees, including Deborah Thompson, Jennifer Aggaboa, Curtis Ruegg, Allen Li, and Connor Gallagher. Submission at 3. Allergan asks that the Special Master compel Revance to provide deposition dates for Mr. Ruegg, Mr. Li, and Mr. Gallagher. Id. at 4. The Parties do not dispute whether the above individuals can be deposed. Indeed, the only dispute between the Parties on this issue seems to be whether a certain witnesses’ electronically stored information must be produced prior to that witnesses’ deposition. See Submission at 10. The rest of the Parties’ briefing on this issue relates to logistical difficulties associated with scheduling the depositions. As to Mr. Gallagher, Revance contends that he will serve as a corporate representative and that it will provide dates for his deposition once the parties have met and conferred regarding the topics in Allergan’s 30(b)(6) deposition notice. Submission at 9. Regarding all witnesses, Revance asks that the Special Master direct both Parties to complete their document production of the witness’s electronically stored information two weeks prior to the scheduled deposition. The Special Master and counsel addressed some of these issues during a status conference held on March 19, 2025. Based on counsel’s comments that they are meeting and conferring about the topics in Allergan’s Rule 30(b)(6) deposition notice and working on a timeline for fact and corporate-representative depositions, the Special Master orders the Parties to continue those discussions to completion and provide a report to the Special Master on or before March 31, 2025 that should include (1) agreed-upon deposition dates for all fact witnesses, including Mr. Gallagher, Mr. Li, and Mr. Ruegg, and (2) the date prior to the deposition by which the party producing the fact witness will complete the production of that witness’s electronically stored information. If the parties fail to reach an agreement by March 31, 2025, they shall submit their disputes to the Special Master for resolution by 5:00 p.m. CDT on March 31, 2025. IV. Conclusion In accordance with the foregoing, the Special Master hereby ORDERS that: 1. Allergan’s February 12, 2025, joint submission to the Special Master is GRANTED in part and DENIED in part as follows: a. Revance SHALL fully respond to Interrogatories No. 10, 21, 22, and 24 on or before April 7, 2025. b. Allergan may replace current interrogatories 20 and 25 with single interrogatories and, if it chooses to do so, it must serve these interrogatories on or before March 31, 2025. Revance will have until April 18, 2025, to serve responses to these two new interrogatories. c. If Allergan wishes to serve more than 25 interrogatories, then it must, on or before April 4, 2025, meet and confer with Revance on the appropriate number. If that meet-and-confer fails to result in a resolution, Allergan may file a motion, in accordance with Local Rule 33.01(b), seeking leave to propound over 25 interrogatories. If Allergan elects to file this motion, it shall do so on or before April 10, 2025. Revance shall file any response on or before April 17, 2025, and Allergan may file a reply brief by April 22, 2025. d. Allergan’s requests with respect to Revance’s responses to RFP Nos. 45, 71, 72, 78, 79, 81, 82, 83, 85, 86, 89, 90, 142–166, 173–179, 184–186, 196, 197, 200, and 236 are DENIED WITHOUT PREJUDICE. Revance SHALL complete its production of documents responsive to the above requests on or before April 7, 2025. e. The Parties shall continue their meet-and-confer discussions regarding deposition-scheduling to completion and provide a report to the Special Master on or before March 31, 2025 that includes (i) agreed-upon deposition dates for all fact witnesses, including Mr. Gallagher, Mr. Li, and Mr. Ruegg, and (ii) the date prior to the deposition by which the party producing the fact witness will complete the production of that witness’s electronically stored information. If the parties fail to reach an agreement by March 31, 2025, they shall submit their disputes to the Special Master for resolution by 5:00 p.m. CDT on March 31, 2025. 2. The Special Master has filed all the briefing and exhibits he has reviewed in conjunction with this Order. The Special Master has filed one of those items under seal because the parties designated it “confidential.” Within fourteen (14) days of the entry of this Order, any party who desires for any material filed under seal in conjunction with this Order to remain under seal SHALL file a motion to seal with the Court pursuant to Local Rule 5.03. 3. Pursuant to paragraph three of the Court’s Order Modifying Case Management Order and Granting Request for the Appointment of a Special Master, the parties have twenty-one (21) days from the date of entry of this Order to file objections or a motion to adopt or modify any of the Special Master’s rulings in this Order. IT IS SO ORDERED. Footnotes [1] The Parties’ February 12, 2025, Submission to the Special Master is attached hereto as Exhibit A. The Submission contained forty-seven exhibits, but it is only necessary to file Submission Exhibits 1, 2, 3, 4, 5, 8, and 9 to resolve the issues raised in the parties’ Submission. Exhibit A, therefore, includes the Submission and only Exhibits 1, 2, 3, 4, 5, 8, and 9. [2] This Order refers to Plaintiffs as “Plaintiffs” and “Allergan” interchangeably. [3] For a more fulsome description of the claims at issue in this lawsuit, see the “General Background” section of the Order of the Special Master Resolving Plaintiffs’ Renewed Motion to Compel Production of Certain Documents (ECF 302). [4] Specifically, Allergan seeks to compel Revance to provide documents responsive to RFP Nos. 45, 71, 72, 78, 79, 81, 82, 83, 85, 86, 89, 90, 142–166, 173–179, 184–186, 196, 197, 200, and 236. [5] These interrogatories are attached to Exhibit A as Exhibits 1, 2, 3, and 4