Apollo Holding Company, LLC et al v. Cliff Roe, et al

1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
APOLLO HOLDING COMPANY,
LLC ET AL.
VERSUS
CLIFF ROE ET AL.
CIVIL ACTION NO. 24-2773
SECTION “N”(3)
ORDER AND REASONS
Before the Court is Defendant Bohr Energy LLC’s (“Bohr”) Motion to Compel
Plaintiff Apollo Holding Company, LLC (“Apollo” or “Plaintiff”), to Provide Complete
Responses to Defendant Bohr’s First Set of Interrogatories (R. Doc. 100), Apollo’s
opposition (R. Doc. 105), and Bohr’s reply (R. Doc. 106). Oral argument took place on
September 29, 2026. For the following reasons, the Motion is GRANTED.
I. 	Background
Apollo, through its predecessor-in-interest, and Defendant Cliff Roe (“Roe”)
jointly executed an Employment Agreement on January 29, 2016, through which Roe
agreed to convey equipment and intellectual property to Apollo. This included:
all 	of 	Employee’s 	equipment, 	demo 	units, 	devices, 	applications,
intellectual property, patents pending and other property whether
related 	to 	the 	Advanced 	Separation 	Gas 	Infusion 	System, 	which
Employee developed, or otherwise. This conveyance specially includes
all of Employee’s property and systems currently in development and
developed in the future, whether the Gas Infusion System or any other
related or unrelated technology. This conveyance also includes any use
currently known or unknown for intellectual property conveyed.1
1 R. Doc. 87 at ¶ 9.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 1 of 17

2
The intellectual property relates to remediation treatment solutions for Hydrogen
Sulfide (“H2S”). H2S—the highly flammable and toxic gas known for its rotten egg
smell—is naturally present within oil and gas wells and is also a by-product of the
petroleum refinery process. Apollo and plaintiff GAPS Technology, LLC2 (“GAPS”,
collectively with Apollo “Plaintiffs”), in part through Roe’s efforts, successfully
developed novel technologies for use in H2S remediation.3
Roe resigned from Apollo on June 21, 2023, with his last date of employment
set for July 6, 2023.4 Apollo alleges Roe represented that his failing health prompted
his retirement. On March 29, 2024, Roe, Apollo, and GAPS executed a Voluntary
Separation Agreement, which “acknowledged Mr. Roe had conveyed intellectual
property in which Apollo and. . . GAPS have exclusive ownership interests.”5 The
agreement was amended on September 5, 2024, to provide Roe with ongoing
payments as a 3% distribution interest holder of Apollo.6 Apollo alleges it agreed to
this distribution interest so that Roe, believed to be in poor health, “would enjoy the
benefits of a large amount of money before he passed away.”7
Rather than retiring, Roe and defendant Kevin Pavlov (“Pavlov”) formed Bohr
Energy, LLC (“Bohr”), which also operates in the H2S remediation industry. Apollo
2 Apollo assigned, transferred, and conveyed all rights, titles, and interests acquired
under the Employment Agreement to GAPS through a corporate restructuring. Id. ¶
11.
3 Id. ¶ 13.
4 Id. ¶ 18.
5 Id. ¶ 25.
6 Id. ¶ 29.
7 Id.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 2 of 17

3
alleges Roe: (1) provided materially misleading representations regarding his health
and intent to retire from the industry; (2) breached his employment agreement by
utilizing intellectual property he had conveyed to Apollos; and (3) is engaged in unfair
trade practices by misappropriating the intellectual and proprietary property of
Apollos in business endeavors with Pavlov and Bohr. Apollo also alleges that Pavlov’s
actions breached a non-disclosure agreement with Apollo (which Pavlov had entered
into in connection with an Apollo site visit) and violated the Louisiana Unfair Trade
Practices Act. Bohr is subject to similar allegations.
Bohr served Interrogatories on Apollo, seeking to clarify the factual basis for
Apollo’s claims. Bohr has categorized the interrogatories as follows:
• 	Identification of Alleged Promises by Roe and Pavlov;
• 	Identification of Intellectual Property;
• 	Identification of Alleged Competition; and
• 	Identification of Damages.8
Apollo objects to many of the requests, arguing that many of these contention
interrogatories are premature or the information sought is within Bohr’s possession,
custody, or control, and that it will supplement these responses in accordance with
the discovery schedule and its continued discovery obligations.9
8 R. Doc. 100-1 at 3.
9 R. Doc. 105 at 4, 11.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 3 of 17

4
II. 	Legal Standard
Unless otherwise limited by court order, Fed. R. Civ. P. 26(b)(1) defines the
scope of discovery: “Parties may obtain discovery regarding any nonprivileged matter
that is relevant to any party’s claim or defense and proportional to the needs of the
case.” A court assesses the proportionality by considering (1) the importance of the
issues at stake in the litigation; (2) the amount in controversy; (3) the parties’
resources; (4) the importance of the proposed discovery in resolving the issues; and
(5) whether the burden or expense of the proposed discovery outweighs its likely
benefit. Id. Information within this scope of discovery need not be admissible in
evidence to be discoverable. Id. “The moving party bears the burden to establish that
the materials requested are within the scope of permissible discovery, after which the
burden shifts to the party resisting discovery to show why the discovery is irrelevant
or otherwise should not be permitted.” Cannon v. CSX Transp., Inc., 2021 WL
5358758, at *1 (E.D. La. Apr. 16, 2021) (citations omitted).
Objections to a discovery request must be stated with specificity and identify
whether any materials are being withheld based on that objection. Fed. R. Civ. P.
33(b)(4); Fed. R. Civ. P. 34(b)(2)(C); Rodriguez-Meza v. Venegas, 2020 WL 14100945,
at *3 (W.D. Tex. Nov. 30, 2020). General boilerplate discovery objections are
insufficient. McLeod, Alexander, Powel & Apffel, P.C. v. Quarles, 894 F.2d 1482, 1485-
86 (5th Cir. 1990).
Under Rule 26(c)(1), courts may restrict discovery “for good cause ... to protect
a party or person from annoyance, embarrassment, oppression, or undue burden or
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 4 of 17

5
expense.” The burden rests on the party objecting to the discovery request to
demonstrate good cause exists to restrict discovery. See Cazorla v. Koch Foods of
Mississippi, LLC, 838 F.3d 540, 549 (5th Cir. 2016) (citing cases). “Discovery rules
are accorded broad and liberal treatment to effect their purpose of adequately
informing litigants in civil trials.” Herbert v. Lando, 441 U.S. 153, 177 (1979).
Discovery rules, though, are subject to the “injunction of Rule 1 that they be construed
to secure the just, speedy, and inexpensive determination of every action.” Id.
(quoting Fed. R. Civ. P. 1). To that end, “the requirement of Rule 26(b)(1) that
material sought be ‘relevant’ should be firmly applied.” Id.
Pursuant to Rule 9(b), a fraud claimant “must state with particularity the
circumstances constituting fraud or mistake.” Indeed, “Rule 9(b) requires the who,
what, when, where, and how to be laid out.” Benchmark Elecs., Inc. v. J.M. Huber
Corp., 343 F.3d 719, 724 (5th Cir. 2003). This is of particular import when analyzing
responses to contention interrogatories. “Failure to provide a rule-compliant response
to a contention interrogatory hinders the discovering party’s ability to conduct follow-
up discovery and to formulate a trial strategy.” V5 Techs. V. Switch, Ltd., 334 F.R.D.
297, 305 (D. Nev. 2019); see also Lawman v. City & City of San Francisco, 159 F.
Supp. 3d 1130, 1140—41 (N.D. Cal. 2016) (excluding theory from summary judgment
motion 	practice 	because 	it 	was 	not 	properly 	identified 	in 	response 	to
contention interrogatory).
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 5 of 17

6
III. 	Analysis
A. 	Unverified Responses and External References
Pursuant to Rule 33(b)(3), parties must answer each interrogatory, to the
extent not objected, “separately and fully in writing under oath.” Verifications are
“critical because ‘interrogatories serve not only as a discovery device but as a means
of producing admissible evidence.’” Whale Capital, L.P. v. Ridgeway, 2024 WL 838505
at *5 (E.D. La. Feb. 28, 2024), reconsideration denied, 2024 WL 894866 (E.D. La. Mar.
1, 2024) (internal citations omitted). Apollo’s responses do not contain the requisite
verification.10 	In its opposition, Apollo fails to address or otherwise resolve this
issue.11 Apollo must provide a verification for all interrogatory responses.12
Bohr 	argues 	that 	Apollo’s 	responses 	impermissibly 	reference 	external
documents such as the second amended complaint.13 Bohr is correct. While Rule 33
permits references to produced business records, it does so where the records are
identified “in sufficient detail to enable the interrogating party to locate and identify
them as readily as the responding party could.” See also Whale Capital, L.P., 2024
WL 838505 at *5 (ordering supplemental responses where answers referenced a
“second amended complaint” and “documents being produced”).
10 R. Doc. 100-4.
11 R. Doc. 105.
12 See e.g., Sterling v. Moran Foods LLC, 2020 WL 14047269 at *2 (E.D. La. Apr. 29,
2020) (requiring verification); Moore v. BASF Corp., 2012 WL 12990571, at *1 (E.D.
La. May 2, 2012) (ordering same).
13 R. Doc. 100-1 at 4.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 6 of 17

7
In ten of its interrogatory answers, Apollo directs Bohr to the “factual
allegations in their Second Amended Complaint,” unspecified documents produced in
this matter, and Plaintiffs’ initial disclosures.14 In one instance, these references
make up the entirety of Apollo’s answer.15 References to external documents,
including particularly the second amended complaint, fail to comply with Rule 33.
Calloway v. H & E Equip., Inc., 2019 WL 13274355, at *2 (E.D. La. May 24, 2019).
To the extent Apollo’s responses refer to pleadings or other discovery documents, it
must supplement its answers to include the information it sought to incorporate via
reference or identify the produced business records “in sufficient detail to enable the
interrogating party to locate and identify them as readily as the responding party
could.” Fed. R. Civ. P. 33.
B. 	Interrogatories
1. 	Identification of alleged promises by Roe and Pavlov
Interrogatory No. 5 asks Apollo to identify the specifics of Roe’s alleged promises
to Apollo. Apollo provided three instances, including the date and substance of alleged
representations, as well as to whom it was made.16 Apollo then went on to discuss
representations made to non-parties and directed Bohr to the second amended
complaint, documents to be produced, and Apollos’ Rule 26 initial disclosures.17
Apollo disputes Bohr’s assertion supplementation is required at this time because it
14 See e.g., R. Doc. 100-4 (Apollo’s Responses to Interrogatories Nos. 5-7, 10-15, and
18).
15 Id. at 8.
16 R. Doc. 100-4 at 6.
17 Id. at 7.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 7 of 17

8
provided substantive answers before directing Bohr to these other documents, and
that contention interrogatories are premature.18
“It is within the court’s discretion to determine the appropriate time for
responding to a contention interrogatory.” Trident Mgmt. Grp., LLC v. GLF Const.
Corp., 2017 WL 3011144 (E.D. La. July 14, 2017). While it is generally true that
contention interrogatories are more appropriately served after a substantial amount
of discovery, that is not always the case. See id. at 3. Litigation began nearly two
years ago. Apollo must supplement its responses to include the alleged instances of
misrepresentations, rather than pointing Bohr back to its pleadings. Bohr is entitled
to discover information about these statements, which are at the heart of Apollo’s
fraudulent inducement claim,
Interrogatory No. 6 asks Apollo to identify the specifics of Pavlov’s alleged
promises 	to 	Apollo. 	Apollo 	did 	not 	provide 	any 	response 	beyond 	referring 	to
extraneous documents and stating it would supplement as necessary under Rule 26.19
References to pleadings are not a sufficient response. Calloway, 2019 WL 13274355,
at *2; see also Adm’rs of the Tulane Ed. Fund, et al. v. Cytogel Pharma, LLC, No. 131
Civ. 16-13987 (E.D. La. Feb. 5, 2018). Apollo must supplement its responses to
provide a substantive answer.
18 R. Doc. 105 at 7—8.
19 R. Doc. 100-4 at 7—8.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 8 of 17

9
2. 	Identification of Intellectual Property
Interrogatory No. 7 states:
Identify 	all 	patents, 	provisional 	patents, 	and 	patent 	applications
prepared, filed, licensed by, or obtained by Plaintiffs since 2016. Please
include in your identification of each the inventor(s), patent number,
provisional patent number, or patent application number or reference
identification number, identify all individuals involved in the research
and development of the product or technology that was patented, the
role of each individual, and the current employment status of each
individual, and identify the date the patent application was submitted,
the date the patent was obtained, and the current status of each patent,
provisional patent, and patent application.20
Apollo provided a list of its patents, identified by number and title, then referred back
to “Plaintiffs’ Discovery Conference Disclosures”21, “the documents produced in this
matter”, and “Plaintiffs’ Initial Disclosures” before stating it would supplement this
response as required.22 Apollo failed to identify any individuals, much less their roles,
or employment status. While Bohr can determine most of the requested information
through the listed patents, the above information remains discoverable.
Interrogatory No. 10 states:
Describe 	in 	detail 	how 	Roe 	had 	been 	planning 	to 	compete, 	was
competing, and/or is currently competing against Plaintiffs while using
the intellectual property that he purportedly conveyed to Plaintiffs and
in 	which 	Plaintiffs 	now 	have 	exclusive 	ownership 	as 	alleged 	in
paragraph 31 of the Complaint. For each item of intellectual property
which Roe is purportedly using to compete with Plaintiffs, identify the
item of intellectual property, the date on which it was conveyed to
Plaintiffs, and the manner in which Roe is purportedly using the item
in an unlawful or actionable manner.23
20 Id. at 8.
21 R. Doc. 74.
22 R. Doc. 100-4 at 10.
23 Id. at 12.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 9 of 17

10
The response describes former Apollo employee Bill White’s conversation with Chris
Jean,24 explaining that “[White], Roe, and Pavlov had visited Major Midstream to test
Roe’s gas blend derived from Apollo’s patented technology.”25 The response also
details Apollo’s knowledge of documents referencing Bohr’s chemical blends or
formulations and treatment processes “that are the same or substantially similar to
the 	technology 	developed 	by 	Roe 	while 	employed 	by 	Apollo 	and 	conveyed 	to
Plaintiffs.”26 Apollo has identified fourteen separate patents or provisional patents
related to its remediation technologies.27 Apollo fails, however, to specify which of the
patents or other technologies were utilized in these demonstrations or documents.
Apollo must supplement its response to Interrogatory 10.
Interrogatory No. 11 states:
Describe the manner in which Bohr is purportedly competing with
Plaintiffs in the oil and gas treatment industry using the intellectual
property conveyed to Plaintiffs as alleged in paragraph 32 of the
Complaint, 	including 	a 	description 	of 	all 	intellectual 	property
purportedly being utilized by Bohr, the date on which the intellectual
property was conveyed to Plaintiffs, and the manner in which Bohr is
purportedly using the intellectual property.28
Apollo’s response is insufficient for two reasons. One, it improperly refers to the
second amended complaint.29 As discussed, these references are not sufficient under
24 Manager of Apollo and Board member of GAPS. R. Doc. 100-4 at 4.
25 Id. at 12.
26 Id. at 13.
27 Id. at 8-10.
28 Id. at 13.
29 Id. at 14.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 10 of 17

11
Rule 33. Further, Apollo responds that it is “in possession of communications and
documents which demonstrate that Bohr Energy, together with Roe and Pavlov, are
marketing that intellectual property to third parties in order to wrongfully profit from
[Apollo’s] intellectual property.”30 Apollo must supplement its response and, to the
extent it has not, produce these communications and documents and describe them
“in sufficient detail to enable the interrogating party to locate and identify them as
readily as the responding party could.” Fed. R. Civ. P. 33; Whale Capital, L.P. v.
Ridgeway, 2024 WL 838505 at *5 (E.D. La. Feb. 28, 2024).
Interrogatory No. 12 states:
Describe the manner in which Pavlov is purportedly competing with
Plaintiffs in the oil and gas treatment industry using the intellectual
property conveyed to Plaintiffs as alleged in paragraph 32 of the
Complaint, 	including 	a 	description 	of 	all 	intellectual 	property
purportedly being utilized by Pavlov, the date on which the intellectual
property was conveyed to Plaintiffs, and the manner in which Pavlov is
purportedly using the intellectual property31
Apollo’s response, similar to its response to Interrogatory No. 11, refers to the second
amended complaint, documents to be produced, and alludes to documents and email
communications involving Pavlov that demonstrate what intellectual property was
misappropriated.32 This response is insufficient for the same reasons as Apollo’s
response to Interrogatory No. 11. Apollo must supplement its response.
30 Id.
31 Id.
32 Id.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 11 of 17

12
Interrogatory No. 13 asks Apollo to identify all intellectual property that Roe
conveyed to Apollo, including:
the date of the conveyance, the manner in which Plaintiffs claim that
Roe allegedly misused or is continuing to use any of that property, the
date 	of 	development 	of 	the 	intellectual 	property, 	the 	individuals
involved in the development of the intellectual property, the patent
numbers (if any), and whether the intellectual property was marked as
proprietary or confidential.33
Apollo objects to this Interrogatory as unduly burdensome and not proportional to the
needs of the case, arguing it would require a review of “a virtually infinite universe
of 	documents 	and 	communications.”34 	The 	remainder 	of 	Apollo’s 	response
impermissibly 	refers 	to 	the 	second 	amended 	complaint 	and 	the 	employment
agreement 	referenced 	therein, 	documents 	to 	be 	produced, 	and 	Apollo’s 	initial
disclosures.35 At this stage of litigation, Bohr is entitled to be put on notice as to what
specific intellectual property Apollo alleges Roe had conveyed and is now misusing.
See V5 Techs. V. Switch, Ltd., 334 F.R.D. 297, 304 (D. Nev. 2019) (“having put
those 	trade 	secrets 	and intellectual property rights 	at 	issue. 	. 	. 	A
contention interrogatory seeking 	identification 	of 	the 	trade 	secrets
and intellectual property on which the [claim] is premised is within the scope of
permissible discovery.”); Strauss v. Credit Lyonnais, S.A., 242 F.R.D. 199, 235 (E.D.
N.Y. May 25, 2007) (“plaintiffs are ordered to disclose the facts and documents that
support the allegations in their complaint”).
33 Id. at 15.
34 Id.
35 Id.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 12 of 17

13
This case was filed in November 2024, and the parties have engaged in
extensive discovery. While Apollo need not “articulate theories which have not yet
been fully developed”, it must supplement its response to (i) include the information
it sought to include via reference to outside materials and (ii) produce and identify
the “evidence” in its possession, custody, or control that it referenced in its response
to Interrogatory No. 14. Id.; see also Pouncil v. Branch Law Firm, 277 F.R.D. 642, 650
(D. Kan. Dec. 13, 2011) (“the Court finds no persuasive reason for Defendants to defer
their answers . . . Defendants should answer these interrogatories as fully as they
can, keeping in mind their continuing obligation to supplement their discovery
responses as additional or different information becomes available.”).
The objection is overruled and Apollo must supplement its response to include
the intellectual property which it alleges Roe misused or is continuing to misuse,
keeping in mind its ongoing obligations to supplement its responses.
3. 	Identification of Alleged Competitive Conduct
Interrogatory No. 14 asks Apollo to identify all information and intellectual
property disclosed to Pavlov that he used to compete against Apollo. Apollo’s Answer
to Interrogatory No. 14 states, in part:
Further, 	Apollo 	has 	evidence 	that 	Roe 	disclosed 	this 	information
subsequent to the termination of his employment with Apollo because
Pavlov is a party to various emails containing content which indicate
that 	Pavlov 	intended 	to 	market 	and 	disclose 	Apollo’s 	proprietary
information and intellectual property to third parties and to use that
information to compete with Apollo36
36 Id. at 16.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 13 of 17

14
This response fails to (i) provide or otherwise identify these emails by date or time,
or (ii) detail what specific proprietary information or intellectual property was
included in the emails. For the reasons explained above, Apollo must supplement this
response to include the information it sought to incorporate via reference and the
underlying factual bases for those allegations.
Interrogatory No. 15 asks Apollo to “describe how Bohr directly competed
with Apollo and/or GAPS.”37 The substantive portion of Apollo’s response identifies
documents it alleges were distributed to Apollo and/or GAPS’ clients that relate to
Apollo’s chemical blends and related treatment processes.38 Apollo must supplement
this response to include the information it sought to incorporate via reference and the
underlying factual bases for those allegations.
Interrogatory No. 18 asks Apollo to identify “each alleged misrepresentation
by Mr. Roe, including the date, the person to whom it was made, and the specific
words used.”39 Apollo objected, arguing that the Interrogatory is “. . . unduly
burdensome to the extent it seeks a verbatim recitation of ‘specific words’ for ‘each
and every’ alleged misrepresentation, and as calling for information beyond what is
proportional to the needs of the case.”40 Apollo alleges a fraudulent inducement claim
against Mr. Roe.41 In claims based in fraud, “Rule 9(b) requires the who, what, when,
where, and how to be laid out.” Benchmark Elecs., Inc. v. J.M. Huber Corp., 343 F.3d
37 R. Doc. 100-4 at 17.
38 Id.
39 Id. at 18.
40 Id. at 19.
41 R. Doc. 87.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 14 of 17

15
719, 724 (5th Cir. 2003). While Apollo may not recall the specific wording of
statements from years ago, Apollo must supplement its response to detail at
minimum the written misrepresentations it has possession, custody, control of; the
substance of spoken communications to the best of its ability (keeping in mind its
ongoing obligations); and identify the documents to which it is referring. See e.g., In
re Bertucci Contracting Co., LLC, 2013 WL 5935154, at *5 (E.D. La. Nov. 5, 2013)
(“claimants cannot merely point to other vast repositories of documents, deposition
transcripts, 	state-court 	pleadings, 	etc. 	and 	inform 	defendants 	to 	search 	the
documents for the information that they want.”); Strauss v. Credit Lyonnais, S.A.,
242 	F.R.D. 	199, 	233 	(E.D. 	N.Y. 	May 	25, 	2007) 	(explaining 	that 	contention
interrogatories “’may ask another party to indicate what it contends, to state all the
facts on which it bases its contentions, to state all the evidence on which it bases its
contentions, or to explain how the law applies to the facts.’”).
Interrogatory No. 21 states:
explain what proprietary information or intellectual property that
Apollo or GAPS contends it owns or enjoys exclusive legal rights to use,
or any research and development performed by Apollo or GAPS, if any,
involving 	electrochemical 	power 	generation 	in 	the 	context 	of
contaminant remediation vis-à-vis the oil and gas industry.42
Apollo’s answer, in part, states “[t]he information provided to Pavlov pursuant to the
NDA has been used by him and the other Defendants as set forth in the Complaint.”43
42 R. Doc. 100-4 at 23.
43 Id.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 15 of 17

16
Apollo must supplement its answer to describe the details it sought to incorporate via
reference.
4. 	Identification of Damages
Interrogatory No. 20 states:
Separately for each cause of action asserted by Plaintiffs, please identify
each 	category 	of 	damages 	Plaintiffs 	are 	seeking 	(i.e., 	actual 	or
compensatory damages, unjust enrichment, entitlement to a reasonable
royalty, and/or any other form of damages), and further state the
theories 	of 	recovery, 	factual 	support 	for 	those 	theories, 	and
computations 	or 	damages 	within 	each 	category, 	and 	identify 	the
witnesses and the evidence Plaintiffs will rely upon in support of same.44
Following oral argument and a status conference, the Court ordered Apollo to
supplement its response to Interrogatory No. 20 and its Initial Disclosures pursuant
to Fed. R. Civ. P. 26(a)(1)(A)(iii).
C. 	Attorneys’ Fees
Bohr requests attorneys’ fees and costs associated with its Motion.45 The Court
will not award attorneys’ fees at this time but will HOLD IN ABEYANCE Bohr’s
request pending further developments in discovery.
IV. 	Conclusion
Accordingly,
IT IS ORDERED that Bohr’s Motion to Compel (Rec. Doc. 100) is GRANTED.
Apollo is ordered to supplement their interrogatory responses as set forth herein,
including with a verification, no later than October 20, 2026.
44 Id. at 22.
45 R. Doc. 100 at 7.
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 16 of 17

17
New Orleans, Louisiana, this 6 th day of October, 2026.
EVA J. DOSSIER
UNITED STATES MAGISTRATE JUDGE
Case 2:24-cv-02773-ASJ-EJD Document 112 Filed 10/07/26 Page 17 of 17