James Duke filed a suit against Pacific Telephone & Telegraph Company (PT&T) and two of its employees for invasion of privacy through unauthorized wiretapping. Duke claimed that defendant's employees bugged his telephone line without his knowledge or consent. Through the use of the bugging devices, defendants acquired information that they communicated to the police department, resulting in his arrest. Although the charges were dismissed, he was discharged from his job. As part of the plaintiff's discovery, oral depositions were taken of the defendant's employees who installed the listening device. These employees refused to answer

(1) Questions relating to the procedure used in making unauthorized tapes of phone conversations (training of personnel, equipment, authority among employees),

(2) Questions relating to the deponents' knowledge of the illegality of unauthorized monitoring,

(3) Questions relating to a possible working relationship between the police and PT&T, and

(4) Questions relating to the monitoring of telephone conversations of subscribers other than the plaintiff. The defendant claimed that these questions were irrelevant to the litigation and therefore not proper matters for discovery. Do you agree?