Defendant's First Set of Interrogatories

GreenLeaf's interrogatories to Vertex Solutions seeking key information about the software development.

Tool Selection Opportunity

Task: Draft additional discovery requests, map requests to elements of proof, anticipate objections

Non-AI Options
  • Form interrogatories (Texas pattern interrogatories)
  • Practice guides with sample discovery requests
  • Secondary sources on discovery strategy
  • Manual mapping of elements to discovery requests
AI Options (Tools You Have)
  • CoCounsel/Protégé: Discovery drafting and analysis within privileged platforms
  • Gemini/Copilot: Can explain discovery concepts—but for Texas-specific rules and limits, what verification is needed?
Selection Considerations
  • Form interrogatories may be faster and more reliable than AI drafting for routine requests
  • Texas has specific limits on interrogatories (Rule 190)—verification required
  • If drafting custom interrogatories, what makes them proper under Texas discovery rules?
  • Consider: Which tool best helps you map discovery to the elements you need to prove?

CAUSE NO. 2026-CV-04521

IN THE DISTRICT COURT OF TRAVIS COUNTY, TEXAS

201ST JUDICIAL DISTRICT

DEFENDANT'S FIRST SET OF INTERROGATORIES TO PLAINTIFF

TO: Plaintiff Vertex Solutions LLC, by and through its attorneys of record, Harrison & Cole LLP

Pursuant to Texas Rules of Civil Procedure 197, Defendant GreenLeaf Technologies, Inc. requests that Plaintiff Vertex Solutions LLC answer the following interrogatories separately and fully, in writing under oath, within thirty (30) days of service.

Definitions

  1. "You," "Your," or "Vertex" refers to Plaintiff Vertex Solutions LLC, including its officers, directors, members, managers, employees, agents, consultants, and any other persons acting on its behalf.
  2. "Software" refers to the inventory management software that is the subject of the Software Development Agreement dated September 8, 2025.
  3. "Agreement" refers to the Software Development Agreement dated September 8, 2025, between Vertex Solutions LLC and GreenLeaf Technologies, Inc.
  4. "Document" has the meaning set forth in Texas Rule of Civil Procedure 192.3(b).
  5. "Communication" means any oral or written exchange of information, including but not limited to conversations, meetings, emails, text messages, letters, and memoranda.

Interrogatories

INTERROGATORY NO. 1: Identify each person involved in the development of the Software, including their name, job title, role in the project, and dates of involvement.

INTERROGATORY NO. 2: Describe in detail the quality assurance and testing procedures used by Vertex to verify that the Software conformed to the specifications in Exhibit A to the Agreement before delivery.

INTERROGATORY NO. 3: State whether Vertex conducted any testing of the Software's inventory tracking accuracy before delivery, and if so, describe the testing methodology and results.

INTERROGATORY NO. 4: State the maximum number of line items the Software's reporting function was designed to handle, and identify any documents that establish or discuss this limitation.

INTERROGATORY NO. 5: Identify each communication between Vertex and GreenLeaf regarding alleged defects in the Software, including the date, participants, method of communication, and substance of each communication.

INTERROGATORY NO. 6: Describe what efforts, if any, Vertex made to investigate or cure the defects identified by GreenLeaf in its January 27, 2026 notice.

INTERROGATORY NO. 7: State Your contention as to what constitutes "acceptable industry tolerances" for inventory tracking accuracy as referenced in Exhibit A to the Agreement, and identify any documents, standards, or authorities that support Your contention.

INTERROGATORY NO. 8: Identify any third-party software, libraries, or code incorporated into the Software, including the source, version, and licensing terms.

INTERROGATORY NO. 9: State whether Vertex has delivered similar inventory management software to any other customers, and if so, identify each customer and state whether any defects or complaints similar to those raised by GreenLeaf were reported.

INTERROGATORY NO. 10: Describe the basis for Vertex's contention that the Software "conforms to the specifications" in Exhibit A to the Agreement, including all facts supporting this contention.

INTERROGATORY NO. 11: Identify each person with knowledge of facts relevant to this lawsuit and describe the subject matter of each person's knowledge.

INTERROGATORY NO. 12: Identify any expert witnesses You intend to call at trial, and for each expert, state their name, qualifications, opinions, and the bases for their opinions.

INTERROGATORY NO. 13: Describe in detail Vertex's document retention policies and practices, including policies regarding the retention of source code, development documentation, testing records, and communications with clients.

INTERROGATORY NO. 14: State the total amount of damages You claim and provide a detailed calculation showing how You arrived at this amount.

INTERROGATORY NO. 15: Identify any insurance policies that may provide coverage for the claims or counterclaims in this lawsuit.