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Contract analysis / opposition-to-motion-to-compel.docx
opposition-to-motion-to-compel.docx
High · 0
Medium · 3
Standard · 1
I. INTRODUCTION
Medium
⚑ Confidentiality undertaking
I. INTRODUCTION Defendant Nexford Industrial Holdings Inc. ("Nexford" or "Defendant"), by and through its attorneys, Calderwood & Harkness LLP, respectfully submits this Response in Opposition to Plaintiff Darren K. Maciejewski's ("Plaintiff") Motion to Compel Production of Documents (the "Motion"), filed on July 22, 2022. For the reasons set forth below, the Court should deny the Motion in its entirety. Plaintiff's
II. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND
II. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND A. Plaintiff's Employment and Termination Plaintiff Darren K. Maciejewski was employed by Nexford as a Quality Assurance Supervisor at the company's Elgin, Illinois manufacturing facility beginning on June 12, 2017. During the course of his employment, Plaintiff was promoted to the position of Senior Quality Assurance Supervisor. Plaintiff remained employed in that capac
III. LEGAL STANDARD
Standard
⚑ Commercial term
III. LEGAL STANDARD Under Illinois Supreme Court Rule 201(b)(1), a party may obtain discovery regarding any matter relevant to the subject matter involved in the pending action, provided that the discovery sought is proportional to the needs of the case. Rule 214, which governs requests for production of documents, is likewise subject to the proportionality and relevance requirements of Rule 201. In assessing proport
IV. ARGUMENT
Medium
⚑ Notice / time limit to track
IV. ARGUMENT A. Plaintiff's Request Is Overbroad and Disproportionate to the Needs of This Case Plaintiff seeks a sweeping production of the complete personnel files of an undefined — and potentially quite large — number of non-party employees, spanning a nearly three-year period from January 1, 2019 through September 24, 2021. The breadth of this request alone warrants its denial. The request is not limited to emplo
V. CONCLUSION
Medium
⚑ Confidentiality undertaking
V. CONCLUSION For all of the foregoing reasons, Defendant Nexford Industrial Holdings Inc. respectfully requests that this Court enter an order denying Plaintiff's Motion to Compel Production of Documents in its entirety. Plaintiff's request for the complete personnel files of all Quality Assurance Department employees who received any form of attendance-related discipline over a nearly three-year period is overbroad