Response builder

Work category-by-category. Open any category to select objections and draft the response. Edits at the category level apply to every request inside; per-request overrides are an exception flow.

Category	Requests	Summary	Status
Policies & Procedures	12	Requests 1–9, 19–21 seek documents relating to Amazon's written policies governing rest breaks, meal periods, overtime, wages, timekeeping, and employee handbooks.	Pending review
	RFP 1	All documents relating to Defendant's rest break policies applicable to COVERED EMPLOYEES during the COVERED PERIOD.	Pending review
	RFP 4	All written policies governing meal-period rights for COVERED EMPLOYEES.	Pending review
	RFP 19	All employee handbooks distributed to COVERED EMPLOYEES during the COVERED PERIOD.	Pending review
Time Data	8	Requests 10, 12, 14–16 seek time records, meal period data, schedules, and rounding records for plaintiff and putative class members.	Pending review
	RFP 10	All time records reflecting hours worked by Plaintiff during the COVERED PERIOD.	Pending review
	RFP 14	All meal period waiver forms signed by CLASS MEMBERS.	Pending review
	RFP 16	Scheduling records for COVERED EMPLOYEES at the affected facilities.	Pending review
Pay Data	6	Requests 11, 13 seek payroll records, wage statements, and compensation data for plaintiff and class members.	Pending review
	RFP 11	All payroll records for Plaintiff during the COVERED PERIOD.	Pending review
	RFP 13	Wage statements issued to CLASS MEMBERS pursuant to Cal. Lab. Code § 226.	Pending review
	ROG 4	State the regular rate of pay for COVERED EMPLOYEES, broken down by job title.	Pending review
Personnel Files	6	Requests 17–18, 24 seek job descriptions, employment dates, and org charts for covered employees.	Pending review
	RFP 17	Job descriptions for all positions held by COVERED EMPLOYEES.	Pending review
	RFP 18	Hire and termination dates for CLASS MEMBERS during the COVERED PERIOD.	Pending review
	RFP 24	Organisational charts reflecting management structure for the COVERED PERIOD.	Pending review
Class Lists	4	Requests 25–28 seek lists and contact information for putative class members.	Pending review
	RFP 25	A list of all CLASS MEMBERS, including names and last-known mailing addresses.	Pending review
	RFP 26	Telephone numbers and email addresses for CLASS MEMBERS.	Pending review
	RFP 28	Work history records reflecting positions held by CLASS MEMBERS during the COVERED PERIOD.	Pending review
Communications	5	Requests 23, 29–31 seek internal communications, complaints, and management directives.	2 flagged
	RFP 23	All written complaints submitted by COVERED EMPLOYEES regarding wage or hour practices.	Flagged
	RFP 29	Internal management directives instructing CLASS MEMBERS to work off-the-clock.	Flagged
	RFP 31	Email communications between supervisors regarding meal-period scheduling for CLASS MEMBERS.	Pending review
Internal Audits	2	Requests 22, 32 seek audit and investigation records relating to timekeeping and wage practices.	Pending review
	RFP 22	Internal audits of timekeeping practices for COVERED EMPLOYEES.	Pending review
	RFP 32	Investigation records relating to wage practices applied to CLASS MEMBERS.	Pending review