Kuniya Tsubota, former VP for HR in IBM Japan, now resides in New York. Why wasn’t that a discovery response?

I am still amazed by this. From the IBM parties’ discovery response last month, I should have received this man’s name—whether or not Paul Hastings firm also desired to object. (“Who committed the tort?” “Sorry, we object to the question.” Like that. [Update: 5/7/12 & 5/12/12: Obviously, the question was not put that way, but rather, the elements were sought out. Still, there was a refusal to answer . . . I don’t think interrogatories are supposed to work by my guessing names, and then the other side saying “nope”.] )

Well, from the few things that various search engines allow me, this man is in Hartsdale, New York, and he works for corporate headquarters of IBM in New York. There is a PDF out there, from early 2009, with him discussing how IBM is a “globally integrated enterprise” (GIE), which means that human resource decisions are not confined to single countries, even if the overall firm is, as they say, committed to the laws of those local countries.

Why wasn’t Mr. Tsubota an answer to one (or several) of the discovery questions? Surprising for him to be working in my country, when I’m still trying to get straight the crooked things done to me in his.