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In a civil action for breach of contract arising from a construction project, the plaintiff serves a set of Interrogatories to the defendant’s Project Engineer seeking (1) the dates and occasions of on-site inspections, (2) criteria used to select subcontractors and suppliers, and (3) internal communications with suppliers regarding material shortages and delivery delays. The defendant objects that several items require professional judgments and that certain responses would disclose confidential methods and proprietary processes. The plaintiff moves to compel. Advise the court and the parties on: (a) the proper mode of discovery and the controlling rule applicable to interrogatories in this context; (b) the scope of discovery in interrogatories and the protective measures that may be ordered (e.g., limiting topics, redaction, sealing, or in‑camera review); (c) the remedies and sanctions available if the interrogatories are denied or the answers are evasive or incomplete.