[jude24]

These are just about 5% of my first set of interrogatories generated by the first sentence of their letter.

If so, your interrogatories would be "unduly burdensome," and they'd be thrown out. Keep it up, and you'd be thrown out for harassment.

For example: Identify how you applied the Generally Accepted Accounting Principles (GAAP) of the American Society of Certified Public Accounts to selecting, conducting and memorializing the results of the “listening” sessions you have claimed to conduct.

They're not accountants. Why would they follow GAAP?

You seem to have lost all objectivity. Let it go.

[MindBender26]

>>>>If so, your interrogatories would be “unduly burdensome,” and they’d be thrown out. Keep it up, and you’d be thrown out for harassment.

Absolutely NOT. When was the last time you saw a 200 page Plaintif's First Set of Interrogitories? That's typical these days in some litigation. Let Defs admit they kept no such records, made no attempt to get statistically fair sample. I have no problem with that... it’s just that they helped me make my case that they were prejudiced against my clients.