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.
Select standard objections to apply specifically to RFP 1. These defaults are inherited from the Class Lists category.
| Inc. | Objection | Scope |
|---|---|---|
| Privileged and/or work product | Standard | |
| Third-party privacy | Employment | |
| Overbroad and unduly burdensome | Boilerplate | |
| Beyond permitted discovery obligations | Boilerplate | |
| Vague and ambiguous | As needed |