Saramiento v. Fresh Harvest, Inc., et al
Filing
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Discovery Order re #63 Joint Discovery Letter Brief. Supplemental Joint Submission due within 15 days of the date of this order. Signed by Judge Susan van Keulen on 7/15/2021. (svklc1S, COURT STAFF) (Filed on 7/15/2021)
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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RIGOBERTO SARAMIENTO, et al.,
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Plaintiffs,
Re: Dkt. No. 63
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FRESH HARVEST, INC., et al.,
Defendants.
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United States District Court
Northern District of California
DISCOVERY ORDER
v.
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Case No. 20-cv-07974-BLF (SVK)
The Parties’ joint submission (Dkt. 63) and supplemental submissions pursuant to Dkt. 64
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identify numerous disputed requests for production, though how many and on what grounds are
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unclear because Plaintiffs’ complaints and Defendants’ objections are scattered throughout the
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submissions and, as such, difficult to discern.1 Further, the proffered charts are not complete and
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not properly formatted and therefore not helpful to the Court. This is not a matter of mere form
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over substance. If the Parties cannot clearly articulate the issues and their respective positions, the
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Court cannot provide guidance and rulings. Accordingly, the Court ORDERS as follows:
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1. Defendants state in Dkt. 63 that with the protective order in place, Fresh Harvest will
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remove redactions on the contracts and invoices it has produced. That is to be done
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immediately and the documents re-produced to Plaintiffs within 7 days of this order.
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Plaintiffs are to re-organize their portion of the joint submission, organizing it into
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categories of related RFPs, identifying the category and the specific requests covered
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by each category. For example: Documents relating to H-2A job orders (Request nos.
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__-__); Documents provided to workers (Request nos. __-__); etc. For each category,
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Plaintiffs are to explain the relevance of the requests and address any issues of
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In addition, Exhibit A reflects RFPs directed to Fresh Harvest and Exhibit B reflects RFPs
directed to SMD Logistics. The RFPs contained in Exhibits A and B are not identical.
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proportionality. Plaintiffs are to provide their portion of the joint submission to
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Defendants within 5 days of this order.
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3. Defendants are to re-organize their portion of the joint submission using Plaintiffs’
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categorized format, inserting their position under Plaintiffs’ position for each category.
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Defendants are to provide their portion to Plaintiffs with 5 days of receiving
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Plaintiffs’ portion. The parties are to meet and confer regarding finalizing and must
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file a Supplemental Joint Submission, not to exceed 8 pages, within 15 days of this
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order.
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4. The Parties are to submit a chart, single-spaced in landscape format that identifies the
request, the response, a brief summary (e.g., 2-3 sentences) of each Party’s position
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United States District Court
Northern District of California
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and offer of compromise presented side-by-side (not vertically), and a column for the
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Court’s ruling. The chart is merely a summary; it is not the place to paste arguments
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from the joint submission. Parties often set forth the request and response with the
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column-formatted positions underneath, to wit:
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Request:________
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Response___________
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Plaintiff’s Position
Defendant’s Position
Proposed
Court Order
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Compromise
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Plaintiff:
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Defendant:
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SO ORDERED.
Dated: July 15, 2021
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SUSAN VAN KEULEN
United States Magistrate Judge
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