Hi and welcome to JA. I am Ray and will be the expert helping you today.
The test here is whether the information requested will lead to relevant information .If you can show that it might even lead to other relevant information the discovery should be allowed.The idea here under the rules is that discovery is very liberal if it even has a possibility that it leads to relevant information being discovered it is proper here.
Your remedy through the court is a motion to compel.The court would decide whether the information falls within the test and is not privileged.The court functions to resolve such discover disputes and may well compel the other party here to answer the question or produce the documents requested as being relevant or leading to relevant information.
Parties may obtain discovery regarding any matter, not
privileged, which is relevant to the subject matter involved in the pending action,
whether it relates to the claim or defense of the party seeking discovery or to the
claim or defense of any other party, including the existence, description, nature,
custody, condition and location of any books, documents, or other tangible things
and the identity and location of persons having knowledge of any discoverable
matter. It is not ground for objection that the information sought will be
inadmissible at the trial if the information sought appears
reasonably calculated to lead to the discovery of admissible evidence.
Here your next move is a motion to compel and a court order to compel them to produce the discovery.
I appreciate the chance to help you today.Please let me know if you have more follow up.Thanks again.