Contract analysis

1. Scope of Production. Each Request calls for all responsive Documents in Plaintiff's possession, custody, or control. The term "possession, custody, or control" shall be interpreted in accordance with California Code of Civil Procedure section 2031.010 et seq. and applicable case law, and includes Documents held by Plaintiff's attorneys, agents, representatives, accountants, consultants, investigators, or any other

2. Electronically Stored Information. These Requests expressly encompass electronically stored information in all forms, media, and formats, including but not limited to emails, text messages, instant messages, social media content (posts, messages, stories, comments, and any other content), documents created in or stored on personal computers, laptops, tablets, smartphones, external hard drives, USB drives, cloud st

3. Time Period. Unless otherwise stated in a particular Request, each Request covers the period from November 1, 2018 through the date of Plaintiff's response to these Requests. Where a Request references the "EMPLOYMENT PERIOD," the applicable time period is March 14, 2019 through August 5, 2022, as defined above.

4. Privilege Log. If any Document responsive to any Request is withheld, in whole or in part, on the basis of any claim of privilege (including but not limited to the attorney-client privilege, the work product doctrine, or any other statutory or common law privilege), Plaintiff shall identify each such Document on a privilege log in compliance with California Code of Civil Procedure section 2031.240(b). The privileg

5. Organization of Production. Documents produced in response to these Requests shall be produced either (a) as they are kept in the ordinary course of business, or (b) organized and labeled to correspond with the categories in these Requests, in accordance with California Code of Civil Procedure section 2031.280. If Documents are produced as they are kept in the ordinary course of business, Plaintiff shall identify

6. Protective Order. Documents produced in response to these Requests may be designated by either party pursuant to the Stipulated Protective Order entered in this action by the Court on February 15, 2023. To the extent Plaintiff believes any responsive Document contains confidential personal information that warrants designation under the Protective Order, Plaintiff is instructed to produce such Document with the ap

7. Continuing Duty to Supplement. To the extent Plaintiff discovers, obtains, or becomes aware of additional Documents responsive to these Requests after serving her initial responses, Plaintiff is obligated to supplement or amend her responses in accordance with California Code of Civil Procedure section 2031.050 and any applicable Court orders. REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST FOR PRODUCTION NO. 1 All D