Plaintiff's Responses to Interrogatories

Vertex Solutions' verified responses containing key admissions and information.

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Although these are opposing party's responses, they relate to your client matter. Apply appropriate confidentiality analysis before using any tool.

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Task: Identify insufficient responses, extract key admissions, prepare motion to compel or deposition questions

Non-AI Options

Manual annotation highlighting admissions, evasions, and inconsistencies
Spreadsheet tracking responses against what was requested
Secondary sources on discovery response sufficiency standards

AI Options (Tools You Have)

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These responses contain matter-specific information—confidentiality analysis required
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The highlighted portions contain potential admissions—what deposition questions would follow up?
Consider: Is AI necessary for this task, or would manual review with annotation be equally effective?

CAUSE NO. 2026-CV-04521

PLAINTIFF'S RESPONSES TO DEFENDANT'S FIRST SET OF INTERROGATORIES

General Objections

Vertex objects to the Definitions and Instructions to the extent they seek to impose obligations beyond those required by the Texas Rules of Civil Procedure. Subject to these objections, Vertex responds as follows:

Responses

INTERROGATORY NO. 1: Identify each person involved in the development of the Software...

RESPONSE: The following individuals were involved in developing the Software:

Daniel Osito, Managing Partner – Project oversight, client communications (September 2025 – January 2026)
Priya Sharma, Lead Developer – Primary software development, architecture design (September 2025 – January 2026)
Kevin Liu, Junior Developer – Front-end development, UI implementation (October 2025 – January 2026)
Maria Santos, QA Analyst – Testing and quality assurance (December 2025 – January 2026)

INTERROGATORY NO. 2: Describe in detail the quality assurance and testing procedures...

RESPONSE: Vertex conducted standard quality assurance testing including: (1) unit testing of individual software components; (2) integration testing of modules working together; (3) user acceptance testing with sample data; and (4) performance testing under typical load conditions. Testing confirmed the Software met the functional requirements in Exhibit A.

INTERROGATORY NO. 3: State whether Vertex conducted any testing of the Software's inventory tracking accuracy...

RESPONSE: Yes. Vertex tested the inventory tracking function using sample datasets. Testing involved entering known quantities and verifying accurate display. Test results showed the system accurately recorded and displayed inventory quantities within acceptable parameters.

INTERROGATORY NO. 4: State the maximum number of line items the Software's reporting function was designed to handle...

RESPONSE: The Software was designed for typical small-to-medium business reporting needs. The specifications in Exhibit A do not establish any minimum or maximum report size. Internal development notes may reference performance parameters, but no specific limitation was communicated to or agreed upon with Defendant.

INTERROGATORY NO. 5: Identify each communication between Vertex and GreenLeaf regarding alleged defects...

RESPONSE:

January 17, 2026 – Email from Maya Chen to Daniel Osito reporting inventory count and reporting issues
January 19, 2026 – Email from Daniel Osito to Maya Chen requesting additional information
January 21, 2026 – Email from Maya Chen to Daniel Osito disputing user error explanation
January 24, 2026 – Email from Daniel Osito to Maya Chen stating software conforms to specifications
January 27, 2026 – Email from Maya Chen to Daniel Osito with formal defect notice and attachments
February 4, 2026 – Email from Daniel Osito to Maya Chen demanding payment
February 4, 2026 – Email from Maya Chen to Daniel Osito stating GreenLeaf will consult attorneys

INTERROGATORY NO. 6: Describe what efforts, if any, Vertex made to investigate or cure the defects...

RESPONSE: Priya Sharma reviewed the documentation provided by GreenLeaf and examined the system logs. Ms. Sharma concluded that the Software was functioning as designed and that the reported issues were likely attributable to user configuration or data entry practices. Because Vertex determined no defect existed, no remediation was necessary.

INTERROGATORY NO. 7: State Your contention as to what constitutes "acceptable industry tolerances"...

RESPONSE: "Acceptable industry tolerances" is a standard term in software development that acknowledges minor variances due to factors such as timing of data synchronization, rounding, and system processing. The term provides reasonable flexibility and does not require perfect accuracy. Vertex is not aware of any single authoritative standard defining this term; its meaning depends on context and reasonable expectations.

INTERROGATORY NO. 8: Identify any third-party software, libraries, or code incorporated into the Software...

RESPONSE: The Software incorporates the following third-party components:

React.js (v18.2) – MIT License
Node.js (v18.x) – MIT License
PostgreSQL database (v15) – PostgreSQL License
Chart.js (v4.0) – MIT License
Various npm packages as standard dependencies – various open-source licenses

INTERROGATORY NO. 9: State whether Vertex has delivered similar inventory management software to any other customers...

RESPONSE: Objection: This interrogatory seeks information regarding confidential business relationships with third parties not relevant to this litigation. Subject to this objection, Vertex states that it has developed software for other clients. Vertex is not aware of any complaints substantially similar to those raised by GreenLeaf.

INTERROGATORY NO. 10: Describe the basis for Vertex's contention that the Software "conforms to the specifications"...

RESPONSE: The Software conforms to the specifications because it: (1) provides real-time inventory tracking across three warehouse locations; (2) generates automated reorder notifications; (3) integrates with QuickBooks; (4) includes a reporting dashboard with customizable reports; and (5) offers a mobile-responsive web interface. Each functional requirement in Exhibit A has been implemented and delivered.

INTERROGATORY NO. 14: State the total amount of damages You claim...

RESPONSE: Vertex claims the following damages:

Unpaid contract balance: $60,000.00
Interest at 1.5% per month from January 15, 2026 through trial (estimated): $4,500.00
Attorneys' fees: To be determined based on actual fees incurred
Total (excluding attorneys' fees): $64,500.00 plus continuing interest