Each sub-part of Interrogatory No. 1 contains a specific quotation from a specific paragraph of Plaintiffs' Second Amended Complaint. Plaintiffs have refused to answer the interrogatory propounded by Defendants. Plaintiffs provide 750 names of individuals with knowledge of paragraphs 54 through 69. In addition to the sheer magnitude of the total number of names, the lists of names of persons with knowledge of specific paragraphs are also very lengthy. For example, Plaintiffs list over 200 names of persons with knowledge of paragraph 55.
Plaintiffs also fail to provide addresses for any of the individuals that they have named.
B. Discussion Plaintiffs have objected to Interrogatory Nos. In particular, they argue that if the Court compels them to answer these interrogatories they will be forced to reveal the names of individuals they interviewed in connection with the preparation of their Complaint. The Court concludes that the interrogatories at issue are appropriate and that Plaintiffs must answer them. The Court will address each of these points in turn. First, the interrogatories do not seek the disclosure of those individuals interviewed by Plaintiffs' counsel.