Oscar Maldonado, J. Miguel Ibarra, Gustavo Gomez, and Faustino Boria (plaintiffs) were salesmen for ICG Telecom Group, Inc. (ICG) (defendant). The plaintiffs alleged that ICG had a policy of not providing service to certain Los Angeles areas based on race, a policy called footprinting. The plaintiffs were either terminated or coerced into resigning, and they sued ICG for employment discrimination. ICG suffered a financial reversal and filed a petition for bankruptcy. Many ICG employees were laid off, including most of the plaintiffs’ former supervisors and many human-resource and management employees. The plaintiffs noticed the depositions of ICG’s person most knowledgeable about several specific areas, including: (1) the reasons for terminating certain plaintiffs, (2) the documents supporting the termination decisions, (3) the identities of the people who participated in the termination decisions, and (4) the footprinting policy. The notices also included document requests for certain personnel files, job descriptions, and correspondence. ICG designated Patricia Haley as the person most knowledgeable about the employment issues and produced her for the deposition. However, Haley: (1) testified that she had little personal knowledge of the termination decisions, (2) would not testify whether a file she was shown was a personnel file, (3) did not bring one requested personnel file, and (4) had zero knowledge about one plaintiff’s employment. Two ICG employees were designated as ICG’s most knowledgeable people about the footprinting policy, but they did not bring any documents and had only general knowledge about the factors usually considered in deciding the sales and service areas. The plaintiffs moved: (1) to compel further depositions and document responses and (2) for evidentiary sanctions. The trial court ordered ICG to provide additional documents but denied the rest of the motion. The plaintiffs appealed.