Defendant Rae’s General Contractors motion to compel Plaintiff Lee Kelley to respond to form interrogatories is GRANTED. Plaintiff Lee Kelley is ordered to provide VERIFIED responses, without objections, to Defendant Rae’s General Contractors form interrogatories within 20 days.

Defendant Rae’s General Contractors motion to compel Plaintiff Lee Kelley to respond to demand for production of documents is GRANTED. Plaintiff Lee Kelley is ordered to provide VERIFIED responses, without objections, to Defendant Rae’s General Contractors demand for production of documents within 20 days.

Plaintiff Lee Kelley and his attorneys of record are to pay a total of $1,440 in sanctions within 30 days.

Moving party is to give notice.