Yes, that is correct. And it’s quite obvious that I never claimed to be an “arbiter” of Discovery policy in either of these senses. The “arbiter” of Discovery policy is Discovery itself. I merely record and report what Discovery has said.
Please move all your future comments on this subject to the new discussion George has created. I will not respond to any future comments on this subject here. It’s a slight to Terrell’s efforts to drag the discussions of her question off-topic in this way.