Professional Documents
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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Cung Le, Nathan Quarry, Jon Fitch, Brandon Case No.: 2:15-cv-01045-RFB-(PAL)
15 Vera, Luis Javier Vazquez, and Kyle
16 Kingsbury on behalf of themselves and all PLAINTIFFS MOTION TO COMPEL
others similarly situated, DEFENDANT TO PRODUCE A LOG OF
17 COMMUNICATIONS FOR DANA
Plaintiffs, WHITES DISCOVERABLE
18 v. TELEPHONE NUMBERS AND
ELECTRONIC COMMUNICATION
19 Zuffa, LLC, d/b/a Ultimate Fighting DEVICES AND DIRECTING
20 Championship and UFC, DEFENDANT TO SUBMIT AN
INVENTORY OF ELECTRONIC
21 Defendant. COMMUNICATION DEVICES
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PLAINTIFFS MOTION TO COMPEL
Case 2:15-cv-01045-RFB-PAL Document 395 Filed 05/09/17 Page 2 of 6
1 Pursuant to Local Rule 26-7 and Fed. R. Civ. P. 37 , Plaintiffs Cung Le, Nathan Quarry,
2 Jon Fitch, Brandon Vera, Luis Javier Vazquez, and Kyle Kingsbury on behalf of themselves and
3 all others similarly situated (collectively, Plaintiffs), hereby move this Court to compel
5 (a) Produce a log, for each mobile telephone and electronic device utilized by Zuffa
6 President Dana White during the Relevant Time Period that may contain relevant ESI,
7 that identifies the time, date and, if applicable, duration, of each communication made
8 on each such device, including the telephone number, email address, social media
11 (b) Submit to the Court and Plaintiffs a written report regarding Defendants
23 b. Whether the device was subject to a litigation hold, the date the
24 litigation hold was implemented and a copy of the litigation hold and
26 c. Whether the device and ESI thereon was inspected by counsel for
27 Defendant;
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PLAINTIFFS MOTION TO COMPEL
Case 2:15-cv-01045-RFB-PAL Document 395 Filed 05/09/17 Page 3 of 6
5 e. Whether ESI was collected from the device, the date of each collection,
6 the date range for the ESI collected from the device and whether the
8 f. For any device from which ESI was not collected and produced to
10 Attached to this Motion as Exhibit 1 is a Proposed Order. The grounds for this motion
11 are set forth in the accompanying (1) Memorandum of Law in Support of Plaintis Motion to
13 Telephone Numbers and Electronic Communication Devices and Directing Defendant to Submit
15 I hereby certify that Plaintiffs have made a good faith effort to resolve the referenced
16 dispute in accordance with Local Rule 26-7 and Fed. R. Civ. P. 37.
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PLAINTIFFS MOTION TO COMPEL
Case 2:15-cv-01045-RFB-PAL Document 395 Filed 05/09/17 Page 4 of 6
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PLAINTIFFS MOTION TO COMPEL
Case 2:15-cv-01045-RFB-PAL Document 395 Filed 05/09/17 Page 5 of 6
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PLAINTIFFS MOTION TO COMPEL
Case 2:15-cv-01045-RFB-PAL Document 395 Filed 05/09/17 Page 6 of 6
1 CERTIFICATE OF SERVICE
2 I hereby certify that on this 9th day of May, 2017 a true and correct copy of
PLAINTIFFS MOTION TO COMPEL DEFENDANT TO PRODUCE A LOG OF
3 COMMUNICATIONS FOR DANA WHITES DISCOVERABLE TELEPHONE
NUMBERS AND ELECTRONIC COMMUNICATION DEVICES AND DIRECTING
4 DEFENDANT TO SUBMIT AN INVENTORY OF ELECTRONIC COMMUNICATION
5 DEVICES was served via email on all parties or persons requiring notice.
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/s/ Michael DellAngelo
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PLAINTIFFS MOTION TO COMPEL