Regardless, the intent of this thread was to find the techniques to force the other side to give up information. I sent out a demand letter pursuant to Fed.R.Civ.P. 26(a)(1)(A)(ii) and they refused to provide any "documentation", saying they were not required. So, they filed a plathora of counterclaims which would require documented support, and failed to disclose those documents in their disclosures and now refuse to provide anything. They're just playing the game because their entire case is about playing the system; nothing more.
I understand I can file a motion to compel with the Court, but I want to be spot on about the representation of such.