I. INTRODUCTION AND BACKGROUND From about 2008 until about 2017, plaintiff Ashley Osucha worked at defendant Alden State Bank (the “Bank”) and held two job titles: Teller and Head Teller. In her complaint, plaintiff asserts that two of the Bank’s officers, defendants Richard Koelbl and John Koelbl, sexually harassed her for several years and discriminated against her with respect to wages, promotions, and other available benefits. Plaintiff has claims against defendants under several statutes, including Title VII of the Civil Rights Act of 1964 (“Title VII”), 42 U.S.C. §§2000e to 2000e-17; and the New York State Human Rights Law (“NYSHRL”), N.Y. Executive Law §§290-301. For the sake of brevity, familiarity with the case is otherwise presumed, including with the details of plaintiff’s allegations of sexual harassment, a hostile work environment, and retaliation. On February 26, 2020, plaintiff filed a motion to compel more detailed responses to various document requests and interrogatories that she had served. (Dkt. No. 45.) Because of the number of issues contained in the motion, the Court will address each component of the motion below. The Court held oral argument on the motion on May 13, 2020. (Dkt. No. 53.) For the reasons below, the Court grants plaintiff’s motion in part, without costs to any party. II. BACKGROUND A. Production of Documents The pending motion is the second motion to compel that plaintiff has filed in the past year. Plaintiff filed the first motion on June 11, 2019. (Dkt. No. 29.) On December 12, 2019, the Court issued a Decision and Order (the “Prior Order”) that adjudicated the first motion. (Dkt. No. 42.) Among other issues addressed, the Court directed defendants to produce certain files created by Bank counsel Hodgson Russ LLP during an internal investigation of plaintiff’s allegations. How defendants responded to the Prior Order now is the focus of the pending motion to compel. According to plaintiff, defendants responded to the Prior Order by producing the following documents: Portions of documents that had been held by Hodgson Russ, LLP, relative to Ashley Osucha (10 pages total); Pages O003682-O003691. Personnel File of Jamie Hey; Pages O003692-O003982. Personnel File of Kaitlyn Chadbourne; Pages O003983-O004120. Personnel File of Julie Osucha; Pages O004121-O004333. Portions of documents that had been held by Hodgson Russ, LLP, relative to Carolyn Sure Aldinger. (Dkt. No. 45-1 at 2.) Plaintiff considers this document production inadequate. In particular, plaintiff has submitted her own affidavit as well as the affidavit of one of defendants’ former officials, Carolyn Sue Aldinger, to provide direct personal knowledge “that the following documents, at least at some point, existed”: Carolyn Sue Aldinger’s typed summaries of interviews with Plaintiff and Kaitlyn Chadbourne, created on or about August 13, 2015, which Carolyn Sue Aldinger gave to Hilde Neubauer, Esq., Vice President/Compliance Officer/General Counsel. See Osucha Aff. 5 (Dkt. 29-14); Aldinger Aff. 7 (Dkt. 29-12); Handwritten notes taken by Emina Poricanin, Esq., a Hodgson Russ, LLP, attorney during an August 20, 2015 interview of Carolyn Sue Aldinger. See Aldinger Aff.
