Case: A.P.F. v. United States

President Donald Trump

DHS Secretary John Kelly

President Donald Trump

COMPLAINT. Filing fee received: $ 400.00, receipt number 0970-17820035 filed by A.P.F., J.V.S. (Beauchamp, Keith) (Attachments: # 1 Civil Cover Sheet)(MFR) (Entered: 01/10/2020)

1 Civil Cover Sheet

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SUMMONS Submitted by A.P.F., J.V.S. (Beauchamp, Keith) (Attachments: # 1 Summons)(MFR) (Entered: 01/10/2020)

Filing fee paid, receipt number 0970-17820035. This case has been assigned to the Honorable Susan M Brnovich. All future pleadings or documents should bear the correct case number: CV-20-0065-PHX-SMB. Notice of Availability of Magistrate Judge to Exercise Jurisdiction form attached. (MFR) (Entered: 01/10/2020)

NOTICE TO THE PARTIES - The Court is participating in the Mandatory Initial Discovery Pilot (MIDP) and this case is subject to that pilot. The key features and deadlines are set forth in the attached Notice which includes General Order 17-08. Also attached is a checklist for use by the parties. All parties must respond to the mandatory initial discovery requests set forth in the General Order before initiating any further discovery in this case. Please note: The discovery obligations in the General Order supersede the disclosures required by Rule 26(a)(1). Any party seeking affirmative relief must serve a copy of the attached documents (Notice to Parties, including General Order 17-08 and MIDP Checklist) on each new party when the Complaint, Counterclaim, Crossclaim, or Third-Party Complaint is served. (MFR) (Entered: 01/10/2020)

Summons Issued as to United States of America, U.S. Attorney and U.S. Attorney General. (Attachments: # 1 Summons)(MFR) (Entered: 01/10/2020)

ORDER that motions pursuant to Fed. R. Civ. P. 12(b) are discouraged if the defect can be cured by filing an amended pleading. The parties must meet and confer prior to the filing of such motions to determine whether it can be avoided. FURTHER ORDERED that Plaintiff(s) serve a copy of this Order upon Defendant(s) and file a notice of service. See attached Order for complete details. Signed by Judge Susan M Brnovich on 1/13/2020. (TCA) (Entered: 01/13/2020)

ORDER: Clerk of Court to terminate any or all Defendants in this matter, without further notice, that have not been served within the time required by Fed. R. Civ. P. 4(m) on April 9, 2020. Signed by Judge Susan M Brnovich on 1/13/2020. (TCA) (Entered: 01/13/2020)

MOTION To Proceed Under Pseudonyms and for a Protective Order, MOTION for Protective Order by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order Order)(Beauchamp, Keith) (Entered: 01/13/2020)

1 Text of Proposed Order Order

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Notice of Deficiency (Text Only)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Michelle Lapointe on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

NOTICE TO FILER OF DEFICIENCY re: 8 MOTION To Proceed Under Pseudonyms and for a Protective Order MOTION for Protective Order filed by A.P.F., J.V.S.. Document not in compliance with LRCiv 7.1(a)(3) - Party names must be capitalized using proper upper and lower case type. No further action is required. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (GMP) (Entered: 01/14/2020)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Terra White Fulham on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Norma Ventura on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Matthew Jay Schlesinger on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark: Pro hac vice motion(s) granted for Swati R Prakash on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Paul R Chavez on behalf of Plaintiffs A.P.F., J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Jason Andrew Carey on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark (Public)

Remark: Out of state attorney Jessica R Hanson removed as counsel of record for noncompliance with admission procedures; party or parties represented by other admitted counsel. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Remark (Public)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Jessica R Hanson on behalf of Plaintiffs A.P.F. and J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

MOTION to Transfer Related Case by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order) (Associated Cases: CV-19-05217-PHX-SRB, CV-20-00065-PHX-SMB) (Beauchamp, Keith) (Entered: 02/14/2020)

RESPONSE to Motion re: (21 in 2:19-cv-05217-SRB, 21 in 2:19-cv-05217-SRB) MOTION to Transfer Related Case filed by C.M., L.G., M.R., O.A., V.C.. (Associated Cases: 2:19-cv-05217-SRB, 2:20-cv-00065-SMB) (Rosenbaum, David) (Entered: 02/20/2020)

NOTICE OF ATTORNEY APPEARANCE: Theodore William Atkinson appearing for United States of America. . (Atkinson, Theodore) (Entered: 02/27/2020)

Notice of Deficiency (Text Only)

RESPONSE IN OPPOSITION TO MOTION TO TRANSFER (ECF 10) by Defendant United States of America. (Atkinson, Theodore) (Entered: 02/27/2020)

NOTICE OF ATTORNEY APPEARANCE: Philip D. MacWilliams appearing for United States of America. . (MacWilliams, Philip) (Entered: 02/27/2020)

NOTICE TO FILER OF DEFICIENCY re: 13 Response filed by United States of America. Document entered in wrong case and wrong event used. This document should have been filed in CV-19-5217 using the LR 42 Response to Motion to Consolidate/Transfer Cases event. FOLLOW-UP ACTION REQUIRED: Please refile document in correct case with correct event. Deficiency must be corrected within one business day of this notice. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (SLQ) (Entered: 02/27/2020)

RESPONSE to Motion re: (21 in 2:19-cv-05217-SRB, 21 in 2:19-cv-05217-SRB) MOTION to Transfer Related Case filed by United States of America. (Associated Cases: 2:19-cv-05217-SRB, 2:20-cv-00065-SMB) (Atkinson, Theodore) (Entered: 02/27/2020)

REPLY to Response to Motion re: (21 in 2:19-cv-05217-SRB) MOTION to Transfer Related Case filed by A.P.F., J.V.S.. (Associated Cases: 2:20-cv-00065-SMB, 2:19-cv-05217-SRB) (Beauchamp, Keith) (Entered: 03/05/2020)

MOTION for Leave to File Excess Pages for motion for excess pages by United States of America. (Attachments: # 1 Text of Proposed Order)(MacWilliams, Philip) (Entered: 03/11/2020)

RESPONSE to Motion re: 18 MOTION for Leave to File Excess Pages for motion for excess pages filed by A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 03/12/2020)

ORDER that the United States' 18 Motion for Leave to File Excess Pages is granted as follows: The page limit is enlarged to permit up to 30 pages for the United States' Motion to Dismiss. IT IS FURTHER ORDERED enlarging the Response page limit to 30 and the Reply page limit to 15. Signed by Judge Susan M. Brnovich on 3/16/2020. (ESG) (Entered: 03/16/2020)

MOTION to Dismiss for Lack of Jurisdiction and Failure to State a Claim by United States of America. (MacWilliams, Philip) (Entered: 03/17/2020)

REPLY to Response to Motion re: (21 in 2:19-cv-05217-SRB) MOTION to Transfer Related Case (Supplement) filed by A.P.F., J.V.S.. (Attachments: # 1 Exhibit 1) (Associated Cases: 2:20-cv-00065-SMB, 2:19-cv-05217-SRB) (Beauchamp, Keith) (Entered: 03/24/2020)

STIPULATION re: 21 MOTION to Dismiss for Lack of Jurisdiction and Failure to State a Claim by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order)(Beauchamp, Keith) (Entered: 03/30/2020)

ORDER that the 23 Stipulation for Extension of Time is GRANTED. Plaintiffs shall file their response on or before 5/18/2020, and the United States shall file its reply on or before 6/17/2020. Signed by Judge Susan M. Brnovich on 3/31/2020. (ESG) (Entered: 03/31/2020)

NOTICE of Attorney Withdrawal Michelle Lapointe filed by Keith Beauchamp. (Beauchamp, Keith) (Entered: 04/01/2020)

ORDER - IT IS ORDERED granting Plaintiffs' Motion to Transfer. (Doc. 10 in CV20-00065 and Doc. 21 in CV19-05217). IT IS FURTHER ORDERED that counsel shall use the case number CV20-00065-PHX-SRB for all further proceedings. Signed by Senior Judge Susan R Bolton on 4/13/2020. (Associated Cases: 2:19-cv-05217-SRB, 2:20-cv-00065-SMB) (WLP) (Entered: 04/14/2020)

ORDER granting 8 Motion to Proceed Under Pseudonyms and for a Protective Order [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 4/16/20. (MAW) (Entered: 04/16/2020)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for Gillian Brett Gillers on behalf of Plaintiffs A.P.F., J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

MOTION to Amend/Correct 1 Complaint by A.P.F., J.V.S.. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Beauchamp, Keith) (Entered: 05/11/2020)

RESPONSE to Motion re: 21 MOTION to Dismiss for Lack of Jurisdiction and Failure to State a Claim filed by A.P.F., J.V.S.. (Tolman, Shelley) (Entered: 05/18/2020)

RESPONSE in Opposition re: 28 MOTION to Amend/Correct 1 Complaint filed by United States of America. (MacWilliams, Philip) (Entered: 05/26/2020)

REPLY to Response to Motion re: 28 MOTION to Amend/Correct 1 Complaint filed by A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 06/02/2020)

REPLY to Response to Motion re: 21 MOTION to Dismiss for Lack of Jurisdiction and Failure to State a Claim filed by United States of America. (MacWilliams, Philip) (Entered: 06/17/2020)

ORDER: IT IS ORDERED granting Plaintiffs' Motion for Leave to File First Amended Complaint and to Add Parties (Doc. 28 ). IT IS FURTHER ORDERED that the Court will maintain the existing briefing schedule for the United States' Motion to Dismiss (Doc. 21 .) The Motion to Dismiss will be considered as directed at the First Amended Complaint [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 7/15/20. (MAW) (Entered: 07/15/2020)

AMENDED COMPLAINT against United States of America filed by A.P.F., J.V.S..(Beauchamp, Keith) (Entered: 07/16/2020)

MOTION to Proceed Using Pseudonyms and for a Protective Order by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order)(Beauchamp, Keith) (Entered: 07/21/2020)

ORDER: IT IS ORDERED denying the United States' Motion and Memorandum in Support of the United States' Motion to Dismiss (Doc. 21 ) [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 7/27/20. (MAW) (Entered: 07/27/2020)

ORDER: Pursuant to Rule 16 of the Federal Rules of Civil Procedure, a Case Management Conference is set for September 3, 2020, at 10:30 a.m. The Rule 16 Case Management Conference will be telephonic. Counsel shall not appear in person. Counsel are directed to call (866) 390-1828; Access code 9667260 five minutes prior to the hearing. Counsel are advised that speaker phones are not permitted [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 7/27/20. (MAW) (Entered: 07/27/2020)

ORDER granting 35 Motion to Proceed Under Pseudonyms and for a Protective Order [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 8/6/20. (MAW) (Entered: 08/06/2020)

ANSWER to 34 Amended Complaint by United States of America.(MacWilliams, Philip) (Entered: 08/10/2020)

MINUTE ORDER: On the Court's own Motion, Telephonic Scheduling Conference is re-set IN TIME ONLY from 10:30 AM to 01:45 PM on 9/3/2020 before Senior Judge Susan R Bolton. Counsel are reminded the call-in information is contained in the Court's Order at Doc. 37 . This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAW) (Entered: 08/21/2020)

~Util - Set/Reset Hearings

Rule 26(f) Report for Mandatory Initial Discovery Pilot (MIDP) Joint Case Management Report filed by Plaintiffs A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 08/27/2020)

Remark re Pro Hac Vice Motion

Remark: Pro hac vice motion(s) granted for James Melvin Knoepp on behalf of Plaintiffs A.P.F., J.V.S.. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (BAS)

Joint MOTION for Protective Order by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order)(Beauchamp, Keith) (Entered: 09/02/2020)

1 Text of Proposed Order

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Joint MOTION FOR ORDER ENTERING CLAWBACK AGREEMENT AND ORDER PURSUANT TO FED. R. EVID. 502(d) by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order)(Beauchamp, Keith) (Entered: 09/02/2020)

1 Text of Proposed Order

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MINUTE ENTRY for proceedings held before Senior Judge Susan R Bolton: Telephonic Scheduling Conference held on 9/3/2020. Discussion held as to the coordination of the case regarding discovery and disclosure with CV 19-05217-PHX-SRB (C.M., et al., v. United States of America) assigned to this Court. IT IS ORDERED directing the parties to meet and confer on a supplemental discovery plan and file said plan no later than October 5, 2020. If the parties are in disagreement, the parties shall set out their position as to why this additional supplemental discovery is needed. IT IS FURTHER ORDERED directing Plaintiffs' counsel in this case, Plaintiffs' counsel in CV 19-05217-PHX-SRB and Defense counsel who are common to both cases to coordinate and be present at all of the common depositions so that there is no duplication of depositions taken in these cases. Rule 16 Scheduling order to issue in this case. APPEARANCES: Keith Beauchamp, Jason Carey, Terra Fulham, Gillian Gillers, Matthew Schlesinger and James Knoepp (all appearing telephonically) for Plaintiffs. Philip MacWilliams (appearing telephonically) for Defendant. (Court Reporter Candy Potter) Hearing held 1:50 PM to 2:18 PM. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAW) (Entered: 09/04/2020)

STIPULATED PROTECTIVE ORDER - See document for complete details. Signed by Senior Judge Susan R Bolton on 9/4/2020. (WLP) (Entered: 09/04/2020)

FEDERAL RULE OF EVIDENCE 502(d) ORDER - IT IS ORDERED pursuant to Rule 502(d) of the Federal Rules of Evidence, Rule 26(b) of the Federal Rules of Civil Procedure, and the Court's inherent authority, the production of a document, or part of a document, shall not constitute a waiver of any privilege or protection as to any portion of that document, or as to any undisclosed privileged or protected communications or information concerning the same subject matter, in this or in any other proceeding. See document for complete details. Signed by Senior Judge Susan R Bolton on 9/4/2020. (WLP) (Entered: 09/04/2020)

1 - Common Prompts (Text Only) AND Scheduling Conference

TRANSCRIPT REQUEST by A.P.F., J.V.S. for proceedings held on 09/03/2020, Judge Susan R Bolton hearing judge(s). (Beauchamp, Keith) (Entered: 09/09/2020)

NOTICE of Service of Responses to Mandatory Initial Discovery (MIDP) filed by Plaintiffs A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 09/10/2020)

NOTICE of Service of Responses to Mandatory Initial Discovery (MIDP) filed by Defendant United States of America. (MacWilliams, Philip) (Entered: 09/10/2020)

SCHEDULING ORDER: Discovery due by 8/27/2021. Dispositive motions due by 4/8/2022 [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 9/10/20. (MAW) (Entered: 09/10/2020)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of TELEPHONIC SCHEDULING CONFERENCE proceedings held on 09/03/2020, before Judge SUSAN R. BOLTON. [Court Reporter: Candy L. Potter, RMR, CRR, Telephone number (602) 322-7246]. The ordering party will have electronic access to the transcript immediately. All others may view the transcript at the court public terminal or it may be purchased through the Court Reporter/Transcriber by filing a Transcript Order Form on the docket before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 10/5/2020. Redacted Transcript Deadline set for 10/15/2020. Release of Transcript Restriction set for 12/14/2020. (RAP) (Entered: 09/17/2020)

TRANSCRIPT REQUEST by United States of America for proceedings held on 9/03/2020, Judge Susan R Bolton hearing judge(s). (MacWilliams, Philip) (Entered: 09/18/2020)

NOTICE of Service of Supplemental Mandatory Initial Discovery Responses (MIDP) filed by Defendant United States of America. (MacWilliams, Philip) (Entered: 10/05/2020)

SUPPLEMENT Joint Supplemental Discovery Plan re: 44 Scheduling Conference, Common Prompts (Text Only) by Plaintiffs A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 10/05/2020)

NOTICE of Errata re: 54 Supplement by Plaintiffs A.P.F., J.V.S... (Beauchamp, Keith) (Entered: 10/05/2020)

ORDER: At the Case Management Conference on September 3, 2020, the Court ordered the parties to meet and confer on a supplemental discovery plan. On October 5, 2020, the parties filed a Joint Supplemental Discovery Plan that outlined their disagreements on policy-level documentary discovery in addition to that being done in the related case of C.M., et al. v. United States, CV19-5217-PHX-SRB, on additional policy-level depositions, and on the number of Plaintiff-specific depositions. Except to the extent specifically authorized by this Order, the Joint Discovery Plan in C.M. et al. v. United States, CV19-5217-PHX-SRB subject to the limitations and clarifications set out in the Court's August 25, 2020 Order in the C.M. case (Doc. 61 ) shall also control the discovery in this case [see attached Order for details]. Signed by Senior Judge Susan R Bolton on 10/29/20. (MAW) (Entered: 10/29/2020)

NOTICE of Service of Discovery filed by A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 11/04/2020)

NOTICE of Service of Supplemental Mandatory Initial Discovery Responses (MIDP) filed by Plaintiffs A.P.F., J.V.S.. (Beauchamp, Keith) (Entered: 11/04/2020)

MOTION to Amend/Correct 56 Order Plaintiffs' Unopposed Motion to Amend Order re Supplemental Discovery Plan by A.P.F., J.V.S.. (Attachments: # 1 Text of Proposed Order Proposed Order Granting Plaintiffs' Unopposed Motion to Amend Order re Supplemental Discovery Plan)(Tolman, Shelley) (Entered: 11/20/2020)

ORDER granting 59 Motion to Amend Order Regarding Supplemental Discovery Plan. Nathalie Asher will be substituted for David Jennings on the list of supplemental policy-level custodians approved by the Court on October 29, 2020. (Doc. 56 .) The Court will allow Plaintiffs to add Nathalie Asher to policy-level searches using seven search strings. Defendant no longer needs to include David Jennings as a policy-level custodian. The remainder of the Court's Order (Doc. 56 ) is unchanged. Signed by Senior Judge Susan R Bolton on 11/23/20. (MAW) (Entered: 11/23/2020)

STATUS REPORT by United States of America. (MacWilliams, Philip) (Entered: 11/25/2020)

ORDER - IT IS ORDERED setting a telephonic status conference on December 3, 2020 at 10:30 for both cases. Counsel shall not appear in person. Counsel are directed to call (866) 390-1828; Access Code: 9667260 five minutes prior to the scheduled hearing. Counsel are advised that speaker phones are not permitted. Signed by Senior Judge Susan R Bolton on 11/25/20. (SLQ) (Entered: 11/25/2020)

REQUEST re: Request for Leave to File Written Response to Status Report Filed by Defendant United States of America by Plaintiff A.P.F.. (Tolman, Shelley) (Entered: 11/30/2020)

ORDER: The Court has reviewed Plaintiffs' Request for Leave to File Written Response to Status Report Filed by Defendant United States of America. IT IS ORDERED that Plaintiffs may file a written response to Defendant's Status Report no later than December 2, 2020. Signed by Senior Judge Susan R Bolton on 12/1/20. (MAW) (Entered: 12/01/2020)

*RESPONSE re: 61 Report - Status Plaintiffs' Response to Status Report Filed By Defendant United States of America by Plaintiff A.P.F., J.V.S. (Tolman, Shelley) *Modified to add additional filer on 12/3/2020 (REK). (Entered: 12/02/2020)

TRANSCRIPT REQUEST by A.P.F. for proceedings held on 12/3/2020, Judge Susan R Bolton hearing judge(s). (Tolman, Shelley) (Entered: 12/03/2020)

MINUTE ENTRY for proceedings held before Senior Judge Susan R Bolton: Telephonic Status Conference held on 12/3/2020 regarding Defendant's Status Report (Doc. 61 ). The Court advises counsel it is aware that Plaintiffs' counsel filed a response to the Status Report (Doc. 65 ) but has not had an opportunity to review the response. Discussion held regarding the status of discovery of electronically stored information. On the Court's own Motion, IT IS ORDERED continuing Telephonic Status Conference to December 10, 2020, at 11:30 a.m. (Arizona time). Counsel are directed to call (866) 390-1828; Access Code: 9667260. Counsel are advised that speaker phones are not permitted. IT IS FURTHER ORDERED directing counsel to submit a joint notice no later than Noon, December 9, 2020 (Arizona time), advising the Court the agreements the parties have reached and what area of disagreements still remain. Defense Counsel should be prepared to advise the Court at the December 10 conference of a proposed timeline to complete the review of the documents and of dates for rolling production of those documents. APPEARANCES: Gillian Gillers, Keith Beauchamp, Terra Fulham, James Knoepp, Norma Ventura and Kristin Cobb (all appearing telephonically) for Plaintiffs. Philip MacWilliams (appearing telephonically) for Defendant. (Court Reporter Linda Schroeder) Hearing held 10:34 AM to 11:07 AM. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAW) (Entered: 12/04/2020)

NOTICE OF FILING OF OFFICIAL TRANSCRIPT of TELEPHONIC STATUS CONFERENCE Proceedings held on 12/03/2020, before Judge SUSAN R. BOLTON. [Court Reporter: Linda Schroeder, RDR, CRR, Telephone number (602) 322-7249]. The ordering party will have electronic access to the transcript immediately. All others may view the transcript at the court public terminal or it may be purchased through the Court Reporter/Transcriber by filing a Transcript Order Form on the docket before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/28/2020. Redacted Transcript Deadline set for 1/4/2021. Release of Transcript Restriction set for 3/4/2021. (RAP) (Entered: 12/07/2020)

1 - Common Prompts (Text Only) AND Status Conference AND ~Util - Set/Reset Hearings

1 - Common Prompts (Text Only) AND ~Util - Set/Reset Hearings AND Status Conference

~Util - Set/Reset Hearings AND 1 - Common Prompts (Text Only) AND Status Conference

STATUS REPORT Joint Status Report by A.P.F.. (Tolman, Shelley) (Entered: 12/09/2020)

MINUTE ENTRY for proceedings held before Senior Judge Susan R Bolton: Telephonic Status Conference held on 12/10/2020. A telephonic status conference was held December 3, 2020, regarding Defendant's status report but was continued to this date in order for counsel to file a Joint Status Report to detail the status of ESI discovery, which has been filed at Doc. 69 . Discussion held. IT IS ORDERED directing Defense counsel to produce to Plaintiffs no later than January 31, 2021, the Department of Justice documents along with the attorney/client privilege log of the documents being withheld. The issue of executive privilege will not be resolved at this time. IT IS FURTHER OERDERED affirming the deadline of December 31, 2020, for the production of Plaintiffs' specific ESI documents. Regarding the Technology Assisted Review Validation Process ("TAR"), IT IS ORDERED the TAR validation process shall be completed no later than January 15, 2021. Defense counsel will then be in a position to advise how long it will take Defense counsel to complete the production with a log and a realistic deadline by when Plaintiffs can expect to receive the documents on a rolling basis. IT IS FURTHER ORDERED directing counsel to file a Joint Status Report no later than February 1, 2021. A further telephonic status conference may be set after the Court reviews the joint status report. APPEARANCES: Gillian Gillers, Keith Beauchamp, Terra Fulham, Jessica Hanson, James Knoepp and Norma Ventura (all appearing telephonically) for Plaintiffs. Philip MacWilliams (appearing telephonically) for Defendant. (Court Reporter Hilda Lopez) Hearing held 11:33 AM to 12:09 PM. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MAW) (Entered: 12/11/2020)

TRANSCRIPT REQUEST by A.P.F. for proceedings held on 12/10/2020, Judge Susan R Bolton hearing judge(s). (Tolman, Shelley) (Entered: 12/11/2020)