Custom Response

RFP No. 1

This request has been flagged for individual response.

Changes made here will only apply to RFP 1 and will not affect other requests in the Class Lists category.

Request for Production No. 1Category: Class Lists

All COMMUNICATIONS between any manager, supervisor, or human resources representative and any CLASS MEMBER regarding meal period, rest break, or overtime complaints during the CLASS PERIOD.

AI Analysis

Complaint Reference

Related to Complaint ΒΆΒΆ 45-48 alleging retaliation claims for reporting labor violations.

Suggested Approach

Consider stronger objection on burden grounds given volume of potential responsive documents across all locations.

Similar Requests

See also RFP 48, 49 (grouped in Class Lists bucket).

View Bucket

Select standard objections to apply specifically to RFP 1. These defaults are inherited from the Class Lists category.

Inc.ObjectionScope
Privileged and/or work productStandard
Third-party privacyEmployment
Overbroad and unduly burdensomeBoilerplate
Beyond permitted discovery obligationsBoilerplate
Vague and ambiguousAs needed
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