Case: Jones v. Chopra

Jones v. Mulvaney

Jones v. Mulvaney

Legal Defense Fund

COMPLAINT CLASS ACTION COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-5688169) filed by CARZANNA JONES, HEYNARD PAZ-CHOW. (Attachments: # 1 Civil Cover Sheet, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(Robot, George) (Entered: 09/13/2018)

1 Civil Cover Sheet

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2 Summons

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3 Summons

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4 Summons

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5 Summons

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Case Assigned to Chief Judge Beryl A. Howell. (zsth)

SUMMONS (4) Issued Electronically as to CONSUMER FINANCIAL PROTECTION BUREAU, JOHN MICHAEL MULVANEY, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zsth) (Entered: 09/16/2018)

STANDING ORDER. Signed by Chief Judge Beryl A. Howell on September 17, 2018. (lcbah1) (Entered: 09/17/2018)

ERRATA CLASS ACTION COMPLAINT by CARZANNA JONES, HEYNARD PAZ-CHOW 1 Complaint, filed by CARZANNA JONES, HEYNARD PAZ-CHOW. (Robot, George) (Entered: 09/17/2018)

NOTICE of Appearance by David A. King, Jr on behalf of All Defendants (King, David) (Entered: 11/20/2018)

MOTION to Dismiss (Counts I, II, V, and VI) by CONSUMER FINANCIAL PROTECTION BUREAU, JOHN MICHAEL MULVANEY (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order)(King, David). Added MOTION to Strike on 11/21/2018 (zrdj). (Entered: 11/20/2018)

Unopposed MOTION for Leave to File Amended Complaint Instanter and Points and Authorities in Support Thereof by CARZANNA JONES, HEYNARD PAZ-CHOW (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Robot, George) (Entered: 12/04/2018)

MINUTE ORDER (paperless) GRANTING the 7 Plaintiffs' Unopposed Motion for Leave to File Amended Complaint Instanter and DENYING, as moot, the 6 Defendants' Partial Motion to Dismiss and Motion to Strike, without prejudice to the defendants filing any renewed motion in relation to the amended complaint. Signed by Chief Judge Beryl A. Howell on December 6, 2018. (lcbah1)

AMENDED COMPLAINT against CONSUMER FINANCIAL PROTECTION BUREAU, JOHN MICHAEL MULVANEY with Jury Demand filed by CARZANNA JONES, HEYNARD PAZ-CHOW.(zrdj) (Entered: 12/07/2018)

ANSWER to 8 Amended Complaint by CONSUMER FINANCIAL PROTECTION BUREAU, JOHN MICHAEL MULVANEY.(King, David) (Entered: 12/20/2018)

MEET AND CONFER STATEMENT. (Attachments: # 1 Text of Proposed Order [proposed] Order)(Robot, George) (Entered: 01/22/2019)

MINUTE ORDER (paperless) DIRECTING, upon consideration of the parties' 10 Joint Meet and Confer Report, the parties to file, by January 28, 2019, a joint status report addressing: (1) why the Court should enter a briefing schedule for motions for class certification prior to resolving the jurisdictional concerns raised in the 10 Joint Meet and Confer Report at 2; and (2) why the plaintiffs' motion for conditional class certification of the Equal Pay Act claim and the plaintiffs' motion for class certification of the Title VII claims cannot follow the same briefing schedule. Signed by Chief Judge Beryl A. Howell on January 24, 2019. (lcbah1)

Set/Reset Deadlines: Joint Status Report due by 1/28/2019. (tg)

Joint STATUS REPORT by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. (King, David) (Entered: 01/28/2019)

MINUTE ORDER (paperless) ISSUING, upon consideration of the parties' 10 Joint Meet and Confer Report and 11 Joint Status Report, the following SCHEDULING ORDER to control the timing of proceedings in this matter: (1) by February 4, 2019, the defendants shall file a brief addressing the Court's jurisdiction over this matter; (2) by February 5, 2019, the parties shall make initial disclosures consistent with Federal Rule of Civil Procedure 26(a)(1); (3) by February 11, 2019, the plaintiffs shall file a brief addressing the Court's jurisdiction over this matter; (4) by April 5, 2019, the plaintiffs shall file any motion for class certification or conditional class certification; (5) by May 3, 2019, the defendants shall file any opposition to class certification or conditional class certification; (6) by May 17, 2019, the plaintiffs shall file any reply in support of class certification or conditional class certification. It is further ORDERED that, within one week of any Court order granting or denying a motion for class certification or conditional class certification, the parties shall file a joint status report proposing a schedule to govern further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on January 28, 2019. (lcbah1)

Set/Reset Deadlines: Defendants' brief regarding jurisdiction due by 2/4/2019; initial disclosures due by 2/5/2019; plaintiffs' brief regarding jurisdiction due by 2/11/2019; Motion for class certification or conditional class certification due by 4/5/2019; opposition to motion, if any, due by 5/3/2019; reply, if any, due by 5/17/2019. (tg)

MEMORANDUM re Order,,,,, by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. (King, David) (Entered: 02/04/2019)

MEMORANDUM re Order,,,,, by CARZANNA JONES, HEYNARD L. PAZ-CHOW. (Robot, George) (Entered: 02/11/2019)

Unopposed MOTION for Extension of Time to File Plaintiffs' Unopposed Motion for Extension of Time to File Briefing Regarding Class Certification or Conditional Class Certification by CARZANNA JONES, HEYNARD L. PAZ-CHOW (Attachments: # 1 Text of Proposed Order)(Robot, George) (Entered: 03/15/2019)

Order on Motion for Extension of Time to File

MINUTE ORDER (paperless) GRANTING the 14 Plaintiffs' Unopposed Motion for Extension of Time to File Briefing Regarding Class Certification or Conditional Class Certification and ISSUING the following SCHEDULING ORDER to control the timing of proceedings in this matter: (1) by May 20, 2019, the plaintiffs shall file any motion for class certification or conditional class certification; (2) by June 17, 2019, the defendants shall file any opposition to class certification or conditional class certification; (3) by July 1, 2019, the plaintiffs shall file any reply in support of class certification or conditional class certification. It is further ORDERED that, within one week of any Court order granting or denying a motion for class certification or conditional class certification, the parties shall file a joint status report proposing a schedule to govern further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on March 15, 2019. (lcbah1)

Set/Reset Deadlines

Set/Reset Deadlines: Plaintiffs' motion for class certification or conditional class certification due by 5/20/2019; defendants' opposition due by 6/17/2019; plaintiffs' reply due by 7/1/2019. (tg)

Joint MOTION for Protective Order by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (Attachments: # 1 Text of Proposed Order)(King, David) (Entered: 04/16/2019)

1 Text of Proposed Order

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Joint MOTION for Order Concerning Materials As To Which Privileges May Be Asserted by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (Attachments: # 1 Text of Proposed Order)(King, David) (Entered: 04/16/2019)

1 Text of Proposed Order

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MINUTE ORDER GRANTING the parties' 15 Joint Motion for Entry of Stipulated Protective Order and ENTERING the parties' Stipulated Protective Order. See attached Order for more details. Signed by Chief Judge Beryl A. Howell on April 16, 2019. (lcbah1) Modified title on 4/18/2019 (tg). (Entered: 04/16/2019)

MINUTE ORDER GRANTING the parties' 16 Joint Motion for Entry of Discovery Order Concerning Materials as to which Privileges May Be Asserted and ENTERING the parties' Discovery Order Concerning Materials as to which Privileges May Be Asserted. Signed by Chief Judge Beryl A. Howell on April 16, 2019. (lcbah1) Modified title on 4/18/2019 (tg). (Entered: 04/16/2019)

NOTICE of Appearance by Thomas Macy McCray-Worrall on behalf of All Defendants (McCray-Worrall, Thomas) (Entered: 04/22/2019)

NOTICE OF WITHDRAWAL OF APPEARANCE as to CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. Attorney David A. King, Jr terminated. (King, David) (Entered: 04/22/2019)

NOTICE OF SUPPLEMENTAL AUTHORITY by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (Attachments: # 1 Exhibit 1 - Memorandum Opinion and Order, Van Atta v. CFPB)(McCray-Worrall, Thomas) (Entered: 05/03/2019)

Joint MOTION for Referral to Mediation and for Stay by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (McCray-Worrall, Thomas) (Entered: 05/09/2019)

Order on Motion for Miscellaneous Relief

Case Stayed

Set/Reset Deadlines

MINUTE ORDER (paperless) GRANTING the parties' 22 Joint Motion for Referral to Mediation and for Stay; REFERRING this matter to the United States District Court Mediation Program until August 8, 2019; STAYING this matter until August 8, 2019; and DIRECTING the parties to file a joint status report by August 8, 2019 advising the Court whether the referral to mediation should be extended or proposing a schedule for further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on May 10, 2019. (lcbah1)

Set/Reset Deadlines: Joint Status Report due by 8/8/2019. (tg)

Case Stayed until 8/8/2019. (tg)

Joint STATUS REPORT and Joint Motion for Extension of Referral to Mediation and Extension of Stay by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. (McCray-Worrall, Thomas) (Entered: 08/08/2019)

Set/Reset Deadlines

.Order

MINUTE ORDER (paperless) GRANTING the parties' 23 Joint Motion for Extension of Referral to Mediation and Extension of Stay; REFERRING this matter to the United States District Court Mediation Program until November 4, 2019; STAYING this matter until November 4, 2019; and DIRECTING the parties to file a joint status report by November 4, 2019 advising the Court whether the referral to mediation should be extended or proposing a schedule for further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on August 8, 2019. (lcbah1)

Set/Reset Deadlines: Case stayed until 11/4/2019; Mediation to conclude by 11/4/2019; Joint Status Report due by 11/4/2019. (tg)

MOTION for Extension of Time by CONSUMER FINANCIAL PROTECTION BUREAU, CARZANNA JONES, KATHLEEN KRANINGER, HEYNARD L. PAZ-CHOW. (See Docket Entry 23 to view document). (znmw) (Entered: 08/13/2019)

Extension of Time to

Joint STATUS REPORT and Joint Motion for Extension of Referral to Mediation and Extension of Stay by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. (McCray-Worrall, Thomas) (Entered: 11/01/2019)

.Order

MINUTE ORDER (paperless) GRANTING the parties' 25 Joint Motion for Extension of Referral to Mediation and Extension of Stay; REFERRING this matter to the United States District Court Mediation Program until January 3, 2020; STAYING this matter until January 3, 2020; and DIRECTING the parties to file a joint status report by January 3, 2020 advising the Court whether the referral to mediation should be extended or proposing a schedule for further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on November 1, 2019. (lcbah1)

JOINT MOTION for Extension of REFERRAL TO MEDIATION AND EXTENSION OF STAY by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (See docket entry 25 to view document)(zrdj) (Entered: 11/04/2019)

Set/Reset Deadlines

Case Stayed

Extension of Time to

Case Stayed until January 3, 2020. (tg)

Set/Reset Deadlines: Joint Status Report due by 1/3/2020. (tg)

MOTION for Extension of Time to Plaintiffs' Unopposed Motion for Extension of Referral to Mediation and Extension of Stay by CARZANNA JONES, HEYNARD L. PAZ-CHOW (Attachments: # 1 Text of Proposed Order)(Robot, George) (Entered: 12/20/2019)

Set/Reset Deadlines

Order on Motion for Extension of Time to

MINUTE ORDER (paperless) GRANTING the plaintiff's 27 Unopposed Motion for Extension of Referral to Mediation and Extension of Stay; EXTENDING the referral for mediation until January 24, 2020; STAYING this matter until January 24, 2020; and DIRECTING the parties to file a joint status report by January 24, 2020 advising the Court whether the referral to mediation should be further extended or proposing a schedule for further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on December 23, 2019. (lcbah1)

Set/Reset Deadlines: Joint Status Report due by 1/24/2020. (hmc)

Joint STATUS REPORT by CARZANNA JONES, HEYNARD L. PAZ-CHOW. (Robot, George) (Entered: 01/24/2020)

Set/Reset Deadlines

.Order

MINUTE ORDER (paperless) ISSUING, upon consideration of the parties' 28 Joint Status Report, the following SCHEDULING ORDER to control the timing of proceedings in this matter: (1) by July 31, 2020, fact discovery on class certification shall close and the parties shall file a joint status report advising the Court whether the parties request referral for mediation or settlement; (2) by September 25, 2020, the parties will produce their expert reports on class certification; (3) by November 20, 2020, the parties will produce their expert rebuttal reports on class certification; (4) by December 18, 2020, the parties shall complete any expert depositions on class certification and the parties shall file a joint status report advising the Court whether the parties request referral for mediation or settlement; (5) by January 29, 2021, the plaintiffs shall file any motion for class certification or conditional class certification; (6) by March 12, 2021, the defendants shall file any opposition to the plaintiffs' motion for class certification; and by (7) April 2, 2021, the plaintiffs shall file any reply in support of class certification. It is further ORDERED that, in the event the plaintiffs file a motion for conditional class certification, the defendants shall have 30 days to respond to any such motion and the plaintiffs shall have 14 days to file any reply to the defendants' response; and that, within one week of any Court order granting or denying a motion for class certification or conditional class certification, the parties shall file a joint status report proposing a schedule to govern further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on January 27, 2020. (lcbah1)

Set/Reset Deadlines: Fact discovery on class certification due by 7/31/2020; expert reports on class certification due by 9/25/2020; expert rebuttal reports on class certification due by 11/20/2020; expert depositions on class certification and status report due by 12/18/2020; plaintiffs' motion for class certification or conditional class certification due by 1/29/2021; defendants' opposition to motion for class certification or conditional class certification due by 3/12/2021; plaintiffs' reply due by 4/2/2021. (tg)

NOTICE of Appearance by Derick Koo Sohn, Jr on behalf of All Defendants (Sohn, Derick) (Entered: 02/19/2020)

NOTICE OF HEARING: The parties shall take notice that a Telephone Conference to address a discovery dispute is scheduled for 5/27/2020, at 12:00 PM before Chief Judge Beryl A. Howell. Telephone conference details will be provided by the deputy clerk via email. (tg)

Notice of Hearing

Minute Entry for proceedings held before Chief Judge Beryl A. Howell: Telephone Conference held on 5/27/2020. (Court Reporter Elizabeth Saint-Loth.) (tg)

MINUTE ORDER (paperless) DIRECTING, upon consideration of the representations and arguments presented in the parties' email submission and at the telephone conference held on May 27, 2020, (1) defendants, by Friday, May 29, 2020, to explain to plaintiffs, in as much detail as possible, (i) what information was in the initial data set provided to plaintiffs, (ii) what information has been added to the data set, such as new people, promotions, and positions, and (iii) why the new information was added to the data set; (2) plaintiffs, by Friday, May 29, 2020, to identify to defendants (i) any outstanding discovery requests to which plaintiffs currently cannot respond and the specific reasons therefor, and an estimated timeframe for response, and (ii) any objections that plaintiffs refuse to withdraw with respect to each outstanding discovery request, and a full explanation of the legal bases for those objections; (3) plaintiffs, by Friday, June 12, 2020, to take any necessary 30(b)(6) deposition concerning changes defendants have made to the data set; and (4) the parties, by Friday, June 19, 2020, to submit a joint status report to the Court on the progress made in complying with this MINUTE ORDER and producing a discovery plan "to secure the just, speedy, and inexpensive determination" of this action. Fed. R. Civ. P. 1. Signed by Chief Judge Beryl A. Howell on May 27, 2020. (lcbah1)

Set/Reset Deadlines: Parties' compliance with Order of the Court due by 5/29/2020; plaintiffs to take any necessary deposition by 6/12/2020; joint status report due by 6/19/2020. (tg)

Telephone Conference

.Order

Set/Reset Deadlines

TRANSCRIPT OF PROCEEDINGS, before Chief Judge Beryl A. Howell, held on 05-27-2020. Page Numbers: 1 - 31. Date of Issuance: 06-05-2020. Court Reporter: Elizabeth SaintLoth; Telephone number: 202-354-3242. Transcripts may be ordered by submitting the Transcript Order FormFor the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, CD or ASCII) may be purchased from the court reporter.NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at www.dcd.uscourts.gov. Redaction Request due 6/26/2020. Redacted Transcript Deadline set for 7/6/2020. Release of Transcript Restriction set for 9/3/2020.(Saint-Loth, Elizabeth) (Entered: 06/05/2020)

NOTICE of Appearance by Allison Ziegler on behalf of All Defendants (Ziegler, Allison) (Entered: 06/10/2020)

Joint STATUS REPORT by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. (Sohn, Derick) (Entered: 06/19/2020)

MINUTE ORDER (paperless) ISSUING, upon consideration of the parties' 32 Joint Status Report and Discovery Plan, the following SCHEDULING ORDER to control the timing of proceedings in this matter: (1) by June 26, 2020, each party will identify to the opposing party any discovery request served prior to June 15, 2020 for which the party disputes the adequacy of the response, and shall serve on the opposing party all additional discovery requests that are necessary for the purposes of fact discovery on class certification; (2) by July 8, 2020, the parties will serve on each other all objections to any new discovery requests; (3) by July 31, 2020, the parties will provide final discovery responses to each other, including production of documents and supplemental privilege logs; (4) by August 10, 2020, the parties will bring any unresolvable discovery disputes to the Court's attention in accordance with the 3 Standing Order, ¶ 7, and will provide notices of depositions, the date(s), time(s), and location(s) of which shall be determined by agreement of the parties; (5) by September 25, 2020, the parties will produce their expert reports on class certification; (6) by November 20, 2020, the parties will produce their expert rebuttal reports on class certification; (7) by December 18, 2020, the parties shall complete any expert depositions on class certification and the parties shall file a joint status report advising the Court whether the parties request referral for mediation or settlement; (8) by January 29, 2021, the plaintiffs shall file any motion for class certification or conditional class certification; (9) by March 12, 2021, the defendants shall file any opposition to the plaintiffs' motion for class certification; and (10) by April 2, 2021, the plaintiffs shall file any reply in support of class certification. It is further ORDERED that, in the event the plaintiffs file a motion for conditional class certification, the defendants shall have 30 days to respond to any such motion and the plaintiffs shall have 14 days to file any reply to the defendants' response; and that, within one week of any Court order granting or denying a motion for class certification or conditional class certification, the parties shall file a joint status report proposing a schedule to govern further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on June 23, 2020. (lcbah1)

MINUTE ORDER (paperless) ISSUING, upon consideration of the parties' 32 Joint Status Report and Discovery Plan, the following SCHEDULING ORDER to control the timing of proceedings in this matter: (1) by June 26, 2020, each party will identify to the opposing party any discovery request served prior to June 15, 2020 for which the party disputes the adequacy of the response, and shall serve on the opposing party all additional discovery requests that are necessary for the purposes of fact discovery on class certification; (2) by July 8, 2020, the parties will serve on each other all objections to any new discovery requests; (3) by July 31, 2020, the parties will provide final discovery responses to each other, including production of documents and supplemental privilege logs; (4) by August 10, 2020, the parties will bring any unresolvable discovery disputes to the Court's attention in accordance with the 3 Standing Order, ¶ 7, and will provide notices of depositions, the date(s), time(s), and location(s) of which shall be determined by agreement of the parties; (5) by September 25, 2020, the parties will produce their expert reports on class certification; (6) by November 20, 2020, the parties will produce their expert rebuttal reports on class certification; (7) by December 18, 2020, the parties shall complete any expert depositions on class certification and the parties shall file a joint status report advising the Court whether the parties request referral for mediation or settlement; (8) by January 29, 2021, the plaintiffs shall file any motion for class certification or conditional class certification; (9) by March 12, 2021, the defendants shall file any opposition to the plaintiffs' motion for class certification; and (10) by April 2, 2021, the plaintiffs shall file any reply in support of class certification. It is further ORDERED that, in the event the plaintiffs file a motion for conditional class certification, the defendants shall have 30 days to respond to any such motion and the plaintiffs shall have 14 days to file any reply to the defendants' response; and that, within one week of any Court order granting or denying a motion for class certification or conditional class certification, the parties shall file a joint status report proposing a schedule to govern further proceedings in this matter. Signed by Chief Judge Beryl A. Howell on June 23, 2020. (lcbah1)

.Order

Set/Reset Deadlines: Set/Reset Deadlines: Each party will by 6/26/2020, identify to the opposing party any discovery request served prior to June 15, 2020 (see Order for details); objections to any new discovery requests due by 7/8/2020; final discovery responses, including production of documents and supplemental privilege logs due by 7/31/2020, parties to bring to the Court's attention any unresolvable discovery disputes, and provide notices of depositions, the date(s), time(s), and location(s) of which shall be determined by agreement of the parties by 8/10/2020; expert reports due by 9/25/2020; expert rebuttal reports due by 11/20/2020; expert depositions on class certification and joint status report due by 12/18/2020; any motion for class certification or conditional class certification due by 1/29/2021; opposition to motion for class certification due by 3/12/2020; reply due by 4/2/2021. (ztg)

Set/Reset Deadlines

NOTICE OF HEARING. The parties shall take notice that a Telephone Conference regarding discovery is scheduled for 7/15/2020, at 11:00 AM before Chief Judge Beryl A. Howell. Connection details will be provided by the deputy clerk. (ztg)

Notice of Hearing

MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Truscenialyn Brooks, Filing fee $ 100, receipt number ADCDC-7336250. Fee Status: Fee Paid. by CARZANNA JONES, HEYNARD L. PAZ-CHOW (Robot, George) (Entered: 07/14/2020)

MINUTE ORDER (paperless) CANCELING the Telephone Conference regarding discovery scheduled for July 15, 2020 at 11:00 AM; GRANTING defendants leave to file a motion for protective order by July 16, 2020 at 5:00 PM, see 3 Standing Order ¶ 7(b); Fed. R. Civ. P 26(b)(2)(B); DIRECTING that any plaintiffs' opposition is due by July 21, 2020 at 5:00 PM and any defendants' reply is due by July 24, 2020 at 5:00 PM; FURTHER DIRECTING that defendants shall, at a minimum, explain: (1) the grounds for their initial objection to the production of electronically stored information ("ESI"); (2) the date by which defendants could complete production of 40,000 pages of ESI; (3) whether defendants believe they can still meet the September 25 deadline for expert reports on class certification if they are required to produce 40,000 pages of ESI; (4) why defendants have not yet completed production of requested congressional testimony and related documents; and (5) whether defendants maintain custodian and source information for documents already produced; and FURTHER DIRECTING that plaintiffs shall, at a minimum, explain or provide: (1) why plaintiffs waited until May and June 2020--after the May 27, 2020 discovery teleconference in this case--to challenge (a) defendants' February 2020 privilege log, and (b) defendants' April 2019 objection to producing ESI; (2) the apparent inconsistency between plaintiffs' denial of knowledge until after defendants' rolling production of documents was complete that defendants had no intention of producing ESI and defendants' asserted objection to the production of ESI in April 2019; (3) the approximate number of pages of ESI plaintiffs believe that defendants still must produce; (4) the necessity for each custodian and search term proposed by plaintiffs; (5) why plaintiffs agreed to a schedule that provided nearly two months between the close of class-certification discovery and the submission of expert reports on class certification given that plaintiffs now maintain they can submit their expert report on class certification within two weeks of receiving a final production of documents from defendants; (6) how plaintiffs have narrowed their class theories over the past two years; (7) why plaintiffs have not responded to defendants' April 2019 interrogatory asking plaintiffs to identify the alleged questions of law and fact common to plaintiffs' purported class (or, alternatively, plaintiffs may provide a response to that interrogatory); (8) a definition of plaintiffs' purported class of "Consumer Response Specialists"; and (9) precisely how plaintiffs' defined purported class of "Consumer Response Specialists" warrants authorizing each aspect of the discovery at issue in the defendants' anticipated motion for a protective order. Signed by Chief Judge Beryl A. Howell on July 14, 2020. (lcbah1)

Set/Reset Deadlines: Motion for protective order due by 5:00 PM on 7/16/2020; opposition due by 5:00 PM on 7/21/2020; Reply due by 5:00 PM 7/24/2020. (ztg)

MINUTE ORDER (paperless) GRANTING plaintiffs' 33 Motion for Admission of Attorney Pro Hac Vice. Ms. Brooks may enter an appearance pro hac vice for the purpose of representing the plaintiffs in this action. Counsel should register for e-filing via PACER and file a notice of appearance pursuant to LCvR 83.6(a). Click for instructions. Signed by Chief Judge Beryl A. Howell on July 14, 2020. ( lcbah1)

.Order

Set/Reset Deadlines

Order on Motion for Leave to Appear Pro Hac Vice

ENTERED IN ERROR.....MOTION for Protective Order by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (Sohn, Derick) Modified on 7/21/2020 (zrdj). (Entered: 07/16/2020)

MOTION for Protective Order by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER (Attachments: # 1 Exhibit Ex. 1, # 2 Exhibit Ex. 2, # 3 Exhibit Ex. 3, # 4 Exhibit Ex. 4, # 5 Exhibit Ex. 5, # 6 Exhibit Ex. 6, # 7 Exhibit Ex. 7, # 8 Exhibit Ex. 8, # 9 Exhibit Ex. 9, # 10 Exhibit Ex. 10, # 11 Exhibit Ex. 11, # 12 Exhibit Ex. 12, # 13 Exhibit Ex. 13, # 14 Exhibit Ex. 14, # 15 Exhibit Ex. 15, # 16 Exhibit Ex. 16, # 17 Exhibit Ex. 17, # 18 Exhibit Ex. 18, # 19 Exhibit Ex. 19, # 20 Exhibit Ex. 20, # 21 Exhibit Ex. 21, # 22 Exhibit Ex. 22, # 23 Exhibit Ex. 23, # 24 Exhibit Ex. 24, # 25 Exhibit Ex. 25, # 26 Exhibit Ex. 26, # 27 Exhibit Ex. 27, # 28 Exhibit Ex. 28, # 29 Exhibit Ex. 29, # 30 Exhibit Ex. 30, # 31 Exhibit Ex. 31, # 32 Exhibit Ex. 32, # 33 Exhibit Ex. 33, # 34 Exhibit Ex. 34, # 35 Exhibit Ex. 35, # 36 Exhibit Ex. 36, # 37 Exhibit Ex. 37, # 38 Exhibit Ex. 38, # 39 Exhibit Ex. 39, # 40 Exhibit Ex. 40, # 41 Exhibit Ex. 41, # 42 Exhibit Ex. 42, # 43 Exhibit Ex. 43, # 44 Exhibit Ex. 44, # 45 Exhibit Ex. 45, # 46 Exhibit Ex. 46, # 47 Exhibit Ex. 47, # 48 Exhibit Ex. 48, # 49 Exhibit Ex. 49, # 50 Exhibit Ex. 50, # 51 Exhibit Ex. 51)(Sohn, Derick) (Entered: 07/16/2020)

NOTICE OF CORRECTED DOCKET ENTRY: re 34 MOTION for Protective Order was entered in error and counsel refiled said pleading as 35 . (zrdj)

ENTERED IN ERROR.....Memorandum in opposition to re 35 MOTION for Protective Order Plaintiffs' Memorandum in Opposition to Defendants' Memorandum of Points and Authorities in Support of Motion for Protective Order filed by CARZANNA JONES, HEYNARD L. PAZ-CHOW. (Attachments: # 1 Exhibit A, # 2 Text of Proposed Order)(Robot, George) Modified on 7/22/2020 (zrdj). (Entered: 07/21/2020)

Memorandum in opposition to re 35 MOTION for Protective Order Plaintiffs' Memorandum in Opposition to Defendants' Memorandum of Points and Authorities in Support of Motion for Protective Order filed by CARZANNA JONES, HEYNARD L. PAZ-CHOW. (Attachments: # 1 Text of Proposed Order, # 2 Exhibit A, # 3 Exhibit 1, # 4 Exhibit 2, # 5 Exhibit 3, # 6 Exhibit 4, # 7 Exhibit 5, # 8 Exhibit 6, # 9 Exhibit 7, # 10 Exhibit 8, # 11 Exhibit 9, # 12 Exhibit 10, # 13 Exhibit 11, # 14 Exhibit 12, # 15 Exhibit 13, # 16 Exhibit 14, # 17 Exhibit 15, # 18 Exhibit 16, # 19 Exhibit 17, # 20 Exhibit 18, # 21 Exhibit 19, # 22 Exhibit 20, # 23 Exhibit 21, # 24 Exhibit 22, # 25 Exhibit 23, # 26 Exhibit 24, # 27 Exhibit 25, # 28 Exhibit 26, # 29 Exhibit 27, # 30 Exhibit 28, # 31 Exhibit 29, # 32 Exhibit 30, # 33 Exhibit 31, # 34 Exhibit 32, # 35 Exhibit 33, # 36 Exhibit 34, # 37 Exhibit 35, # 38 Exhibit 36, # 39 Exhibit 37, # 40 Exhibit 38, # 41 Exhibit 39, # 42 Exhibit 40, # 43 Exhibit 41, # 44 Exhibit 42, # 45 Exhibit 43, # 46 Exhibit 44, # 47 Exhibit 45, # 48 Exhibit 46, # 49 Exhibit 47, # 50 Exhibit 48, # 51 Exhibit 49, # 52 Exhibit 50, # 53 Exhibit 51)(Robot, George) (Entered: 07/21/2020)

Notice of Corrected Docket Entry

NOTICE OF CORRECTED DOCKET ENTRY: re 36 Memorandum in Opposition, was entered in error and counsel has refiled said pleading as docket entry 37 . (zrdj)

Notice of Corrected Docket Entry

MOTION for Leave to File Motion for Leave to File Plaintiffs' Supplemental Memorandum in Opposition to Defendants' Motion for Protective Order Instanter by CARZANNA JONES, HEYNARD L. PAZ-CHOW (Attachments: # 1 Exhibit A, Plaintiffs' Supplemental Memorandum in Opposition to Defendants' Motion for Protective Order, # 2 Exhibit 52, # 3 Exhibit 53)(Robot, George) (Entered: 07/23/2020)

Memorandum in opposition to re 38 MOTION for Leave to File Motion for Leave to File Plaintiffs' Supplemental Memorandum in Opposition to Defendants' Motion for Protective Order Instanter filed by CONSUMER FINANCIAL PROTECTION BUREAU, KATHLEEN KRANINGER. (Sohn, Derick) (Entered: 07/23/2020)