Case: Fairley v. McDonald's Corporation

Legal Defense Fund

COMPLAINT filed by Jamelia Fairley, Ashley Reddick; Jury Demand. Filing fee $ 400, receipt number 0752-16925751. (Attachments: # 1 Exhibit A- Fairley's Charge of Discrimination, # 2 Exhibit B- Fairley's EEOC Dismissal and Notice of Suit Rights, # 3 Exhibit C- Reddick's Charge of Discrimination, # 4 Exhibit D- Reddick's EEOC Dismissal and Notice of Suit Rights)(Werman, Douglas) (Entered: 04/10/2020)

1 Exhibit A- Fairley's Charge of Discrimination

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2 Exhibit B- Fairley's EEOC Dismissal and Notice of Suit Rights

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3 Exhibit C- Reddick's Charge of Discrimination

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4 Exhibit D- Reddick's EEOC Dismissal and Notice of Suit Rights

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CIVIL Cover Sheet (Werman, Douglas) (Entered: 04/10/2020)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Douglas M. Werman (Werman, Douglas) (Entered: 04/10/2020)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Maureen Ann Salas (Salas, Maureen) (Entered: 04/10/2020)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Sarah Jean Arendt (Arendt, Sarah) (Entered: 04/10/2020)

CASE ASSIGNED to the Honorable Virginia M. Kendall. Designated as Magistrate Judge the Honorable Beth W. Jantz. Case assignment: Random assignment. (rc, )

NOTICE TO THE PARTIES - The Court is participating in the Mandatory Initial Discovery Pilot (MIDP). The key features and deadlines are set forth in this Notice which includes a link to the (MIDP) Standing Order and a Checklist for use by the parties. In cases subject to the pilot, all parties must respond to the mandatory initial discovery requests set forth in the Standing Order before initiating any further discovery in this case. Please note: The discovery obligations in the Standing Order supersede the disclosures required by Rule 26(a)(1). Any party seeking affirmative relief must serve a copy of the following documents (Notice of Mandatory Initial Discovery and the Standing Order) on each new party when the Complaint, Counterclaim, Crossclaim, or Third-Party Complaint is served. (pk, ) (Entered: 04/13/2020)

MINUTE entry before the Honorable Virginia M. Kendall. Initial status hearing set for 7/15/2020 at 9:00 a.m. Joint Status Report due by 7/9/2020. The parties are directed to Judge Kendall's web page found at www.ilnd.uscourts.gov for information about the Initial Status Report and for information regarding all standing orders for cases on Judge Kendall's docket. The parties shall follow all of the standing orders for Judge Kendall and all Local Rules which can be found at the same web page. For the Initial Status Report, the parties are to report on the following: (1) Possibility of settlement in the case; (2) if no possibility of settlement exists, the nature and length of discovery necessary (with specific dates) to get the case ready for trial; 3) whether the parties jointly consent to proceed before the Magistrate Judge. At the Initial Status Hearing, the Parties shall be prepared to inform the Court about the extent of monetary damages in order for the Court to address the proportionality of discovery as required by Fed. R. Civ. P. 26. Lead counsel is directed to appear at this status hearing. Mailed notice (lk, ) (Entered: 04/14/2020)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-16930262. (Leonard, Danielle) (Entered: 04/14/2020)

MINUTE entry before the Honorable Virginia M. Kendall. Attorney Danielle E. Leonard's Motion to appear pro hac vice 8 is granted. Mailed notice (lk, ) (Entered: 04/15/2020)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Danielle Evelyn Leonard (Leonard, Danielle) (Entered: 04/15/2020)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-16934059. (Vissers, Elizabeth) (Entered: 04/15/2020)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-16934276. (Cervantez, Eve) (Entered: 04/15/2020)

MINUTE entry before the Honorable Virginia M. Kendall. Attorneys Elizabeth Vissers and Eve Cervantez's Motions to appear pro hac vice 11 and 12 are granted. Mailed notice (lk, ) (Entered: 04/16/2020)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Elizabeth Michelle Vissers (Vissers, Elizabeth) (Entered: 04/16/2020)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Eve H. Cervantez (Cervantez, Eve) (Entered: 04/16/2020)

ORDER Third Amended General Order 20-0012 IN RE: CORONAVIRUS COVID-19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on April 24, 2020. All open cases are impacted by this Third Amended General Order. Parties are must carefully review all obligations under this Order, including the requirement listed in paragraph number 5 to file a joint written status report in most civil cases. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 4/24/2020: Mailed notice. (docket9, ) (Entered: 04/27/2020)

ORDER ORDER Fourth Amended General Order 20-0012 IN RE: CORONAVIRUS COVID-19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on May 26, 2020. This Order does not extend or modify any deadlines set in civil cases. For non-emergency motions, no motion may be noticed for presentment on a date earlier than July 15, 2020. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 5/26/2020: Mailed notice. (docket10, ) (Entered: 05/26/2020)

FIRST AMENDED complaint by Jamelia Fairley, Ashley Reddick against McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Werman, Douglas) (Entered: 06/04/2020)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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4 Exhibit D

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WAIVER OF SERVICE returned executed by Jamelia Fairley, Ashley Reddick. McDonald's Corporation waiver sent on 6/4/2020, answer due 8/3/2020. (Werman, Douglas) (Entered: 06/09/2020)

WAIVER OF SERVICE returned executed by Jamelia Fairley, Ashley Reddick. McDonald's Restaurants of Florida, Inc. waiver sent on 6/4/2020, answer due 8/3/2020. (Werman, Douglas) (Entered: 06/09/2020)

WAIVER OF SERVICE returned executed by Jamelia Fairley, Ashley Reddick. McDonald's USA, LLC waiver sent on 6/4/2020, answer due 8/3/2020. (Werman, Douglas) (Entered: 06/09/2020)

ATTORNEY Appearance for Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC by Jonathan Christian Bunge (Bunge, Jonathan) (Entered: 06/23/2020)

ATTORNEY Appearance for Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC by Daniel R. Lombard (Lombard, Daniel) (Entered: 06/23/2020)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-17135422. (Sheth, Manisha) (Entered: 06/23/2020)

MINUTE entry before the Honorable Virginia M. Kendall. Attorney Manisha Sheth'sMotion to appear pro hac vice 24 is granted. Mailed notice (lk, ) (Entered: 06/24/2020)

MINUTE entry before the Honorable Virginia M. Kendall. By request of parties, Initial Status hearing is reset for 9/14/2020 at 9:00 AM. The courtroom deputy will contact Parties if hearing will proceed via Teleconference. Joint Status Report due by 9/9/2020. Mailed notice (lk, ) (Entered: 06/29/2020)

ORDER Fifth Amended General Order 20-0012 IN RE: CORONAVIRUS COVID-19 PUBLIC EMERGENCY Signed by the Chief Judge Rebecca R. Pallmeyer on July 10, 2020. This Order does not extend or modify any deadlines set in civil cases. No motions may be noticed for in-person presentment; the presiding judge will notify parties of the need, if any, for a hearing by electronic means or in-court proceeding. See attached Order. Signed by the Honorable Rebecca R. Pallmeyer on 7/10/2020: Mailed notice. (Clerk9, Docket) (Entered: 07/10/2020)

MOTION by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC for extension of time to File Response to Plaintiffs' First Amended Complaint (Bunge, Jonathan) (Entered: 08/03/2020)

MINUTE entry before the Honorable Virginia M. Kendall. Defendant's Unopposed Motion for extension of time to file Response to first amended Complaint 28 is granted. Answer shall be filed by 8/17/2020. Mailed notice (lk, ) (Entered: 08/06/2020)

MOTION by Defendants McDonald's USA, LLC, McDonald's Corporation, McDonald's Restaurants of Florida, Inc. to dismiss Plaintiffs' First Amended Complaint (Bunge, Jonathan) (Entered: 08/17/2020)

MEMORANDUM by McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC in support of motion to dismiss 30 (Bunge, Jonathan) (Entered: 08/17/2020)

MOTION by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC to strike Plaintiffs' Class Allegations (Bunge, Jonathan) (Entered: 08/17/2020)

MEMORANDUM by McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC in support of motion to strike 32 Plaintiffs' Class Allegations (Bunge, Jonathan) (Entered: 08/17/2020)

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC (Bunge, Jonathan) (Entered: 08/17/2020)

MINUTE entry before the Honorable Virginia M. Kendall. By agreement of Parties, Briefing schedule set as follows regarding Defendants' Motion to Dismiss 30 and Motion to Strike Plaintiffs' Class Allegations 32 : Responses due by 9/21/2020; Replies due by 10/12/2020. Status hearing set for 11/30/2020 at 9:00 AM. Initial Status hearing set for 9/14/2020 at 9:00 AM stands and will proceed via Teleconference. Prior to the conference call, Please click on this hyper link: https://teleconference.uc.att.com/ecm/?bp=4044432170&mac=2413900 to take you to Judge Kendall's telephone conference login. From there, join conference As Guest, ENTER YOUR NAME, Type the digits in the picture, Click on the Call Me option and fill in your phone number (no hypens) and NAME. If you do not have access to a computer Dial: (877)848-7030, the access code is: 2413900#. Given the increased volume of users that is anticipated, we ask that you keep your phone on mute until your case is called. Please also remember to SAY YOUR NAME EACH AND EVERY TIME BEFORE YOU SPEAK. The Court prefers that you use the procedure that requires that the system calls your phone and you enter your name so that the Court and the Court reporter can see who is speaking during the hearing.Mailed notice (lk, ) (Entered: 08/21/2020)

STATUS Report (Joint) by Jamelia Fairley, Ashley Reddick (Werman, Douglas) (Entered: 09/09/2020)

MINUTE entry before the Honorable Virginia M. Kendall. Teleconference Initial Status hearing held on 9/14/2020. Discovery is stayed until 11/30/2020. Teleconference Status hearing set for 11/30/2020 at 9:00 AM stands. Mailed notice (lk, ) (Entered: 09/15/2020)

RESPONSE by Plaintiffs Jamelia Fairley, Ashley Reddick to motion to strike 32 (Plaintiffs' Response to Defendants' Motion to Strike Plaintiffs' Class Allegations) (Attachments: # 1 Exhibit A)(Werman, Douglas) (Entered: 09/21/2020)

RESPONSE by Plaintiffs Jamelia Fairley, Ashley Reddick to motion to dismiss 30 (Plaintiffs' Response to Defendants' Motion to Dismiss Plaintiffs' First Amended Complaint) (Attachments: # 1 Exhibit One, # 2 Exhibit Two, # 3 Exhibit Three)(Werman, Douglas) (Entered: 09/21/2020)

EXECUTIVE COMMITTEE ORDER: GENERAL ORDER 20-0027: Pursuant that to the Executive Committee Order entered on September 23, 2020 the civil cases on the attached list have been selected for reassignment to form the initial calendar of the Honorable Franklin U. Valderrama; therefore IT IS HEREBY ORDERED that the attached list of 371 cases be reassigned to the Honorable Franklin U. Valderrama; and IT IS FURTHER ORDERED that all parties affected by this Order must review the Honorable Franklin U. Valderrama's webpage on the Court's website for the purpose of reviewing instructions regarding scheduling and case management procedures; and IT IS FURTHER ORDERED that any civil case that has been reassigned pursuant to this Order will not be randomly reassigned to create the initial calendar of a new district judge for twelve months from the date of this Order; and IT IS FURTHER ORDERED that the Clerk of Court is directed to add the Honorable Franklin U. Valderrama to the Court's civil case assignment system during the next business day, so that he shall receive a full share of such cases. Case reassigned to the Honorable Franklin U. Valderrama for all further proceedings. Honorable Virginia M. Kendall no longer assigned to the case. Signed by Honorable Rebecca R. Pallmeyer on 9/28/2020.(docket3, ) (Entered: 09/28/2020)

REPLY by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC to motion to dismiss 30 Plaintiffs' First Amended Complaint (Attachments: # 1 Appendix of Unpublished Cases)(Sheth, Manisha) (Entered: 10/12/2020)

REPLY by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC to motion to strike 32 Plaintiffs' Class Allegations (Attachments: # 1 Exhibit 1 - Bolden, Brief and Appendix of Plaintiff-Appellees, # 2 Appendix of Unpublished Cases)(Sheth, Manisha) (Entered: 10/12/2020)

MINUTE entry before the Honorable Franklin U. Valderrama: Telephonic status hearing set for 11/30/2020 is stricken and reset to 12/10/2020 at 9:30 a.m. The call-in number is (888) 808-6929 and the access code is 5348076. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice (axc). (Entered: 11/03/2020)

TRANSCRIPT OF PROCEEDINGS held on 09/14/2020 before the Honorable Virginia M. Kendall. Initial Status Hearing. Order Number: 39172. Court Reporter Contact Information: Gayle A. McGuigan, CSR, RMR, CRR, (312) 435-6047, Gayle_McGuigan@ilnd.uscourts.gov. IMPORTANT: The transcript may be viewed at the court's public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through the Court Reporter/Transcriber or PACER. For further information on the redaction process, see the Court's web site at www.ilnd.uscourts.gov under Quick Links select Policy Regarding the Availability of Transcripts of Court Proceedings. Redaction Request due 11/25/2020. Redacted Transcript Deadline set for 12/7/2020. Release of Transcript Restriction set for 2/2/2021. (McGuigan, Gale) (Entered: 11/04/2020)

MINUTE entry before the Honorable Franklin U. Valderrama: Telephonic status hearing set for 12/10/2020 is stricken and reset to 2/9/2021 at 10:00 a.m. The call-in number is (888) 808-6929 and the access code is 5348076. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Mailed notice (axc). (Entered: 12/07/2020)

MINUTE entry before the Honorable Franklin U. Valderrama: Telephonic status hearing set for 2/9/2021 is stricken and a status hearing is reset for 3/30/2021 at 9:30 a.m. but to track the case only (no appearance is required; the case will not be called). Mailed notice (axc). (Entered: 02/08/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: Tracking status hearing set for 3/30/2021 is stricken and reset for 5/18/2021 at 9:30 a.m. but to track the case only (no appearance is required; the case will not be called). Mailed notice (axc). (Entered: 03/29/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: Tracking status set for 5/18/2021 is stricken. The court will rule on Defendants' Motion to Dismiss 30 and Motion to Strike Plaintiffs' Class Allegations 32 via CM/ECF. Mailed notice (axc). (Entered: 05/18/2021)

Notice of Supplemental Authority by McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC in Support of Defendants' Motion to Strike Plaintiffs' Class Allegations (Attachments: # 1 Exhibit A)(Sheth, Manisha) (Entered: 06/15/2021)

MEMORANDUM Opinion and Order: For the reasons in the accompanying Opinion, Defendants' Motion to Dismiss 30 is denied. Defendants' Motion to Strike 32 is also denied. Defendants have until August 10, 2021 to answer the First Amended Complaint. The parties are instructed to submit a joint status report on or before August 17, 2021. Signed by the Honorable Franklin U. Valderrama on 7/20/2021. Mailed notice (axc). (Entered: 07/20/2021)

MOTION by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC for extension of time to Answer the First Amended Complaint and File the Joint Status Report (Unopposed) (Sheth, Manisha) (Entered: 08/05/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: Defendants' unopposed motion for an extension of time to answer the first amended complaint (FAC) and file the joint status report 51 is granted. The due date to file Defendants' answer to the FAC and the parties' joint status report is extended to 9/10/2021. Mailed notice (axc). (Entered: 08/09/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: On joint email request of the parties, the parties' joint status report deadline 52 is extended to 9/17/2021. Mailed notice (axc). (Entered: 09/10/2021)

ANSWER to amended complaint by McDonald's Corporation(Sheth, Manisha) (Entered: 09/13/2021)

ANSWER to amended complaint by McDonald's USA, LLC(Sheth, Manisha) (Entered: 09/13/2021)

ANSWER to amended complaint by McDonald's Restaurants of Florida, Inc.(Sheth, Manisha) (Entered: 09/13/2021)

STATUS Report Under Rule 26(f) (Joint) by McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC (Sheth, Manisha) (Entered: 09/17/2021)

ATTORNEY Appearance for Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC by Elizabeth Bethea McRee (McRee, Elizabeth) (Entered: 10/01/2021)

ATTORNEY Appearance for Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC by Efrat R Schulman (Schulman, Efrat) (Entered: 10/01/2021)

MOTION by Attorney Jonathan C. Bunge, Manisha M. Sheth & Daniel R. Lombard to withdraw as attorney for McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC. No party information provided (Sheth, Manisha) (Entered: 10/01/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: The Court has reviewed the parties' joint initial status report 57 and refers discovery supervision, including setting all deadlines, and settlement matters to Magistrate Judge Jantz. Additionally, the motion to withdraw as Defendants' counsel filed by Jonathan C. Bunge, Manisha M. Sheth & Daniel R. Lombard 60 is granted. Mailed notice. (kp, ) (Entered: 10/08/2021)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Beth W. Jantz for the purpose of holding proceedings related to: discovery supervision, including setting all deadlines, and settlement matters. Mailed notice. (kp, ) (Entered: 10/08/2021)

EXECUTIVE COMMITTEE ORDER: Honorable Beth W. Jantz no longer assigned to the case. Signed by Executive Committee on 10/13/21. (nsf, ) (Entered: 10/13/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: In light of the Executive Committee Order of 10/13/2021 63, the Court refers discovery supervision, including setting all deadlines, and settlement matters to Magistrate Judge Cox. Mailed notice (axc). (Entered: 10/14/2021)

Pursuant to Local Rule 72.1, this case is hereby referred to the calendar of Honorable Susan E. Cox for the purpose of holding proceedings related to: discovery supervision, including setting all deadlines, and settlement matters. (axc) Mailed notice. (Entered: 10/14/2021)

ATTORNEY Appearance for Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC by Jennifer Wilcynski Plagman (Plagman, Jennifer) (Entered: 10/18/2021)

NOTICE by Jamelia Fairley, Ashley Reddick Request to Withdraw Appearance of Elizabeth Vissers (Vissers, Elizabeth) (Entered: 10/18/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: The request to withdraw the appearance of Elizabeth Vissers as counsel for Plaintiffs 67 is granted. The parties are reminded that future requests to withdraw an attorney appearance should be filed as "motions" rather than "notices." See N.D. Ill. Local Rule 83.17. Mailed notice (axc). (Entered: 10/19/2021)

MINUTE entry before the Honorable Susan E. Cox: This case has been referred to Judge Cox for discovery management and a settlement conference. The Court has reviewed the parties' Rule 26(f) report. The Court sets a fact discovery deadline of 9/30/22, certain fact discovery related to class member damages and Plaintiffs' request for injunctive relief. It is not the Court's practice to subdivide fact discovery or to set additional dates until it becomes clear the fact discovery deadline will be met. The parties are ordered to file an updated joint status report on 1/17/22 informing the Court of the progress of fact discovery and whether a settlement conference would be fruitful at that time. Mailed notice (mjc, ) (Entered: 10/19/2021)

MOTION by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC for protective order Joint Motion for Agreed Confidentiality Order (Attachments: # 1 Exhibit 1)(Plagman, Jennifer) (Entered: 10/19/2021)

MINUTE entry before the Honorable Susan E. Cox: Joint Motion for Agreed Confidentiality Order 70 is granted. Enter order. Mailed notice (mjc, ) (Entered: 10/20/2021)

AGREED Confidentiality Order. Signed by the Honorable Susan E. Cox on 10/20/2021.Mailed notice(mjc, ) (Entered: 10/20/2021)

MINUTE entry before the Honorable Susan E. Cox: CORRECTED MINUTE ORDER. This case has been referred to Judge Cox for discovery management and a settlement conference. The Court has reviewed the parties' Rule 26(f) report. The Court sets a fact discovery deadline of 9/30/22, except certain fact discovery related to class member damages and Plaintiffs' request for injunctive relief. It is not the Court's practice to subdivide fact discovery or to set additional dates until it becomes clear the fact discovery deadline will be met. The parties are ordered to file an updated joint status report on 1/17/22 informing the Court of the progress of fact discovery and whether a settlement conference would be fruitful at that time. Mailed notice (mjc, ) (Entered: 10/20/2021)

MOTION by Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC for order Joint Motion for Agreed FRE 502(d) Order (Attachments: # 1 Exhibit 1 - Proposed 502(d) Order)(Plagman, Jennifer) (Entered: 10/20/2021)

MINUTE entry before the Honorable Susan E. Cox: Joint Motion for Agreed FRE 502(d) Order 74 is granted. Mailed notice (mjc, ) (Entered: 10/21/2021)

STIPULATED Order Governing the Disclosure of Documents Pursuant Fed. R. Evid. 502(d). Signed by the Honorable Susan E. Cox on 10/21/2021.Mailed notice(mjc, ) (Entered: 10/21/2021)

MOTION for Leave to Appear Pro Hac Vice Filing fee $ 150, receipt number 0752-18797911. (Collins, Nicole) (Entered: 10/22/2021)

MINUTE entry before the Honorable Franklin U. Valderrama: Attorney Nicole S. Collins's motion for leave to appear pro hac vice 77 is granted. Mailed notice (axc). (Entered: 11/17/2021)

ATTORNEY Appearance for Plaintiffs Jamelia Fairley, Ashley Reddick by Nicole Sara Collins (Collins, Nicole) (Entered: 11/17/2021)

STATUS Report Updated Joint Status Report by Jamelia Fairley, Ashley Reddick (Cervantez, Eve) (Entered: 01/18/2022)

MINUTE entry before the Honorable Susan E. Cox:The Court has reviewed the parties' joint status report. The parties have responded to each other's written discovery and have begun document production, which they expect to be completed within the next 30 days. The parties plan to meet and confer regarding deficiencies in their respective responses, and are reminded of this Court's procedures for discovery motions, which require a face-to-face meeting prior to any motions to compel are filed; videoconferencing will satisfy this requirement. The parties are ordered to file an updated joint status report on 3/17/22. Mailed notice (gw, ) (Entered: 01/19/2022)

STATUS Report JOINT by Jamelia Fairley, Ashley Reddick (Cervantez, Eve) (Entered: 03/17/2022)

MINUTE entry before the Honorable Susan E. Cox: The Court has reviewed the parties' joint status report. The parties continue to meet and confer regarding deficiencies in their respective responses and may file a motion to compel if they cannot reach an agreement. The Court reminds the parties of FRCP 37(a)(5), which requires the Court to award the winning side fees and costs unless the losing party's position was substantially justified or awarding fees and costs would be unjust. This minute order will serve as notice of this Court's consideration of that rule, and both parties should be prepared to be heard on this issue if the Court rules against them on any forthcoming motions. The fact discovery deadline of 9/30/22 remains set, except certain fact discovery related to class member damages and Plaintiffs' request for injunctive relief. The parties are ordered to file an updated joint status report on 6/16/22. Mailed notice (gw, ) (Entered: 03/18/2022)

ATTORNEY Appearance for Defendants McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC by Katelyn Nicasio (Nicasio, Katelyn) (Entered: 03/23/2022)

JOINT STIPULATION REGARDING ELECTRONICALLY STORED INFORMATION PROTOCOL FOR DISCOVERY AND PROPOSED ORDER - Signed by the Honorable Susan E. Cox on 3/28/2022: Mailed notice (gw, ) (Entered: 03/28/2022)

STATUS Report JOINT by Jamelia Fairley, Ashley Reddick (Cervantez, Eve) (Entered: 06/16/2022)

MINUTE entry before the Honorable Susan E. Cox: The Court has reviewed the parties' joint status report. They continue to produce written discovery and documents and anticipate being able to resolve any issues that arise. They have taken named Plaintiffs' depositions and a 30(b)(6) deposition has been noticed for Defendant's representative. Discovery appears to be progressing smoothly. he fact discovery deadline of 9/30/22 remains set, except certain fact discovery related to class member damages and Plaintiffs' request for injunctive relief. The parties are ordered to file an updated joint status report on 9/15/22. Mailed notice (gw, ) (Entered: 06/17/2022)

MINUTE entry before the Honorable Susan E. Cox: Discovery conference set for 9/14/22 at 10:30 a.m. The hearing will be held live in Judge Cox's courtroom. Mailed notice (lxs, ) (Entered: 09/08/2022)

MINUTE entry before the Honorable Susan E. Cox: Discovery hearing held. The 9/30/22 discovery deadline remains set, but the parties have indicated that they plan to file a joint motion to extend that deadline; the Court will review that request once it is filed. The principle discovery dispute presented to the Court concerned the geographic scope of class discovery that Defendant is required to produce. At this stage in the litigation, the scope of relevance and the parties' related discovery obligations are defined by the allegations in the complaint; this is particularly true given the District Judge's ruling on Defendant's motion to strike certain class allegations. As such, Defendants are ordered to provide discovery relating to all corporate owned and operated McDonald's stores in the state of Florida, and the Court rejects Defendants' arguments that discovery should be limited to smaller geographic areas such as "profit centers" or "patches." As discussed in open court, the Court does not find that the burden of producing such information outweighs its likely benefit. The Court strikes the joint status report date of 9/15/22 and the Court will set additional deadlines after reviewing the forthcoming motion to extend the fact discovery deadline. (rbf, ) (Entered: 09/14/2022)

MOTION by Plaintiffs Jamelia Fairley, Ashley Reddick for extension of time (JOINT Motion to Extend Discovery Cut-off Deadline) (Arendt, Sarah) (Entered: 09/21/2022)

MINUTE entry before the Honorable Susan E. Cox: Joint Motion to Extend the Fact Discovery Deadline 90 is granted. The fact discovery deadline (except for certain discovery regarding putative class member damages and Plaintiffs' claim for injunctive relief) is extended to 2/15/23. The parties are ordered to file and updated joint status report on 12/15/22 informing the Court on the progress of fact discovery. Mailed notice (lp, ) (Entered: 09/22/2022)

STATUS Report (UPDATED Joint Status Report and Joint Motion for Extension of Fact Discovery Deadline) by Jamelia Fairley, Ashley Reddick (Arendt, Sarah) (Entered: 12/13/2022)

MINUTE entry before the Honorable Susan E. Cox: The Court has reviewed the parties' joint status report. For the reasons discussed therein, the fact discovery deadline (except for certain discovery regarding putative class member damages and Plaintiffs' claim for injunctive relief) is extended to 3/31/23. This is the second time the Court has extended that deadline. NO FURTHER EXTENSIONS WILL BE GRANTED. The parties are ordered to file an updated joint status report on 3/14/23 informing the Court on the progress of fact discovery and whether the parties believe a settlement conference would be fruitful at that time. Mailed notice. (exr, ) (Entered: 12/14/2022)

MINUTE entry before the Honorable Susan E. Cox:Discovery conference set for 10:30 a.m. on 3/9/23 in Courtroom 1025. The hearing will be limited to a maximum of 60 minutes. The parties may each file their own individual position paper on the outstanding discovery issues not to exceed 10 pages. Those papers must be filed on or before 3/6/23. (rbf, ) (Entered: 03/01/2023)

Position Statement Regarding Discovery Dispute STATEMENT by Jamelia Fairley, Ashley Reddick (Arendt, Sarah) (Entered: 03/06/2023)

Discovery Position STATEMENT by McDonald's Corporation, McDonald's Restaurants of Florida, Inc., McDonald's USA, LLC (Attachments: # 1 Exhibit Declaration of Elizabeth B. McRee)(McRee, Elizabeth) (Entered: 03/06/2023)

MINUTE entry before the Honorable Susan E. Cox:The in-person discovery conference set for 3/9/2023 is reset to begin at 10:45 a.m. in courtroom 1025. The hearing will be limited to 60 minutes. Please note, TIME CHANGE ONLY. (rbf, ) (Entered: 03/09/2023)

STATUS Report JOINT by Jamelia Fairley, Ashley Reddick (Cervantez, Eve) (Entered: 03/14/2023)

MINUTE entry before the Honorable Susan E. Cox:Discovery Conference held 3/9/23. Plaintiffs seek discovery related to the resignation or firing of former McDonald's Corporation CEO Steve Easterbrook and former McDonald's Corporation Chief People Officer David Fairhurst. The Court does not believe such discovery is relevant and will not order its production. The materials at issue here could have two potential sources of relevance, neither of which justify production, particularly at this late stage of discovery. The first argument is that other human resources professionals at McDonald's Corporation, McDonald's USA, or McDonald's Florida were aware of Easterbrook's and Fairhurst's sexual harassment, and, as a result, there was an understanding within the broader corporate structure that sexual harassment would not be taken seriously by those employees charged with investigating such behavior. Plaintiffs contend that this attitude would then permeate to all levels, including to the individual Florida stores at issue in this case. However, there is no evidence at this point that any of the human resources employees responsible for handling Plaintiffs' sexual harassment claims were aware of Easterbrook's or Fairhurst's activities, so this argument has no real merit. Plaintiffs' second argument is that Easterbrook's and Fairhurst's activities generally demonstrate a corporate culture that was permissive of sexual harassment across the board and that the existence of such culture bolsters their contention that sexual harassment claims were ignored or not taken seriously. Although it may be true that such a culture existed, the specific facts relating to the termination of Easterbrook and Fairhurst -- which is what the discovery at issue seeks -- are not more or less likely to prove that fact. The existence of that culture can be established through testimony of human resources employees who oversaw sexual harassment claims, probing their experiences with how claims and training were handled, or developing testimony that people below Easterbrook and Fairhurst understood through their interactions with them that sexual harassment might be tolerated or taken less seriously that it should be. Plaintiffs have been free to pursue these inquiries. But the specific facts relating to the termination of these employees are not more or less likely to prove the existence of such a culture unless those employees charged with the responsibility were aware of these facts. Plaintiffs essentially are arguing that the alleged sexual misconduct of two high level employees tends to show that such misconduct would be tolerated at every level of the McDonalds' corporate structure which includes McDonalds Corporation, McDonalds USA, and the actual stores where the putative class members worked. Even if the Court stretched to find such an assertion plausible thus making the discovery sought marginally relevant, the distance between the C-suite at McDonald's Corporation to the daily experience at individual stores in Florida is just too great to find such discovery proportional to the needs of the case pursuant to Rule 26(b). The Court also notes that the allegation that McDonalds Corporation is a joint employer does not on its own make these materials relevant absent a more direct connection to the case. Finally, the production of these materials at the very end of fact discovery would require defendants to rebut the "general permissiveness" claim and accordingly, expand and length of discovery further. Such an expansion is not warranted here. The discovery deadline of 3/31/23 remains set. The status report date of 3/14/23 is stricken and re-set to 3/31/23. (rbf, ) (Entered: 03/23/2023)