In Whitesell Corporation v. Electrolux Home Products, Inc. et. al., Case No. 103-050 (S.D. Ga., Sept. 10, 2015), Plaintiff’s Interrogatory No. 58 sought identification of every person with knowledge of the Defendants’ document retention policies and who had knowledge of Defendants’ efforts to preserve and produce documents. Defendant Electrolux identified three individuals, including Jason Edwards,