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Contract analysis / subpoena-novapay.docx
subpoena-novapay.docx
High · 1
Medium · 3
Standard · 0
1. Date for Production. All documents and electronically stored information responsive to
Medium
⚑ Notice / time limit to track
1. Date for Production. All documents and electronically stored information responsive to the categories described in Section D below shall be produced on or before March 3, 2023. This date is twenty-three (23) days from the date of issuance of this subpoena, which exceeds the minimum statutory notice period prescribed by California Code of Civil Procedure Section 2020.410(c).
2. Time. 10:00 a.m. Pacific Time.
2. Time. 10:00 a.m. Pacific Time.
3. Place for Production. Documents and electronically stored information responsive to thi
3. Place for Production. Documents and electronically stored information responsive to this subpoena shall be produced at the following location: Calderwood & Harkness LLP 777 South Flower Street, Suite 4200 Los Angeles, California 90017 Attention: Devon Archer / Nadia Petrov At the option of the custodian of records, and in lieu of in-person delivery, production may be made by transmitting documents and electronical
4. Manner of Compliance. Pursuant to California Code of Civil Procedure Section 2020.430,
4. Manner of Compliance. Pursuant to California Code of Civil Procedure Section 2020.430, the custodian of records of NovaPay Solutions Inc. may comply with this subpoena for the production of business records by delivering copies of the business records described herein, together with an affidavit of the custodian of records executed in compliance with Evidence Code Section 1561, in lieu of personal appearance at th
5. Protective Order. All documents and electronically stored information produced in respo
Medium
⚑ Liability cap to check against exposure
5. Protective Order. All documents and electronically stored information produced in response to this subpoena are subject to the Stipulated Protective Order entered in this action on February 15, 2023 (the "Protective Order"), a copy of which has been provided to NovaPay concurrently with this subpoena. The Protective Order governs the treatment of confidential and proprietary business information and limits the use
6. ESI Protocol. The production of electronically stored information ("ESI") in response t
Medium
⚑ Notice / time limit to track
6. ESI Protocol. The production of electronically stored information ("ESI") in response to this subpoena shall comply with the ESI Protocol Stipulation and Order entered in this action on January 13, 2023 (the "ESI Protocol"), a copy of which has been provided to NovaPay concurrently with this subpoena. In accordance with the ESI Protocol, the following format specifications apply: (a) Structured Data (including dat
1. NovaPay Solutions Inc.
1. NovaPay Solutions Inc. Attention: Marcus Yee, Director of Client Data Services 2200 Powell Street, Suite 600 Emeryville, California 94608 Manner of Service: BY PERSONAL SERVICE. I caused a true and correct copy of the above-referenced documents to be personally delivered to Marcus Yee at the above address by a registered process server (Golden State Legal Services, Inc.) on February 8, 2023. Additionally, a courte
2. Castellano Byrne & Salas LLP (Counsel for Plaintiffs)
2. Castellano Byrne & Salas LLP (Counsel for Plaintiffs) Attention: Marco Castellano, Esq. / Diane Salas, Esq. 11755 Wilshire Boulevard, Suite 900 Los Angeles, California 90025 Manner of Service: BY ELECTRONIC SERVICE. I caused a true and correct copy of the above-referenced documents to be transmitted via electronic mail to Marco Castellano at mcastellano@infirmfirm.com and to Diane Salas at dsalas@infirmfirm.com on
3. Veltrano Employment Law Group PC (Co-Counsel for Plaintiffs)
High
⚑ Penalty / liquidated damages
3. Veltrano Employment Law Group PC (Co-Counsel for Plaintiffs) Attention: Sandra Higuera, Esq. 350 South Grand Avenue, Suite 2800 Los Angeles, California 90071 Manner of Service: BY ELECTRONIC SERVICE. I caused a true and correct copy of the above-referenced documents to be transmitted via electronic mail to Sandra Higuera at shiguera@ridgemontlaw.com on February 8, 2023. Co-counsel for Plaintiffs have consented to
1. All clock-in and clock-out (punch) records for AMA's California non-exempt employees;
1. All clock-in and clock-out (punch) records for AMA's California non-exempt employees;
2. All records reflecting the application of automatic meal period deductions to AMA empl
2. All records reflecting the application of automatic meal period deductions to AMA employee time records;
3. All records reflecting the use of the Missed Meal Attestation Feature by AMA employees
3. All records reflecting the use of the Missed Meal Attestation Feature by AMA employees;
4. All system configuration records related to
4. All system configuration records related to