Thanks for your efforts Silver.

This motion to compel edigital to produce documents it has already produced is just part of the game that lawyers, engineers, and other professional consultants play among themselves, billing hourly at the customer's expense. Not to be too cinical here, but I am in an environment where we pay our consultants, and we also pay our opposition's consultants, and I see the games every day. Your issues progress to resolution only after the consultants feel they have extracted their pound of flesh.

The bottom line always is - does your consultant give you the best value for your money. It is difficult to change horses in the middle of the race.

At any rate, the motion to compel is meaningless in the grand scheme of the legal proceedings, and has no bearing on outcome of the case, in my opinion.