Consider the following question I received from a defense attorney.

“Plaintiff timely served updated verified responses to Form Interrogatories, Set #1, #6.4, 8.4, 8.6, 16.1- 16.8 and 17.1 (RFA #5) pursuant to a Supplemental Interrogatory request.  Instead of providing the information requested in the interrogatories, Plaintiff responded to each of the interrogatories with the following response: