Requests & Definitions

Extracted requests and defined terms for Whitfield v. SwiftCart.

Requests

All requests extracted from the selected source. Use Category and Sub-category to confirm where each request has been grouped.

#	Request text	Category	Sub-category

Plaintiff's verbatim definitions and how we'll interpret them in our responses. Edits persist into response drafting.

Term	Plaintiff's definition	Our interpretation
PLAINTIFF	"Named plaintiff Dana Whitfield."
DEFENDANT / YOU / YOUR	"SwiftCart Logistics, LLC, its agents, employees, insurance companies, attorneys, and anyone acting on its behalf."	Overbroad — improperly sweeps in insurers, attorneys, and unrelated agents. Defendant will respond only as to SwiftCart Logistics, LLC and its agents/employees acting within the scope of the matters at issue.
WAGE STATEMENT	"An itemized statement in writing required to be issued to an employee in relation to each pay period."	Defendant interprets this as the itemized wage statement required under Labor Code § 226(a); the undefined "non-exempt California employees" population and varying date ranges (Dec 1, 2019 vs Dec 8, 2017) are not limited to Plaintiff or to a certified class.
PERSON / PERSONS	"Any individual, business, corporation, association, partnership, or any other entity whatsoever."
DOCUMENT	"Any writing as defined in Cal. Evid. Code § 250 and FRE 1001(a) — any recorded communication or representation."
COMMUNICATE / COMMUNICATION	"Any exchange of information, written or oral — calls, letters, mail, email, voicemail, texts, notes, etc."
IDENTIFY	"(persons) name + all contact info; (documents) description, location, present custodian; (facts) all relevant info."