Lee v. Walmart, Inc. et al

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
ARIEL LEE, an individual,
Plaintiff,
V.
WALMART INC.; WAL-MART
ASSOCIATES, INC.; and DOES 1 through 20,
inclusive,
Defendants.
Case No. 4:25-cv-08157-AMO
[PROPOSED] ORDER ON JOINT
STATEMENT REGARDING
DISCOVERY DISPUTES
Judge: Hon. Araceli Martinez-Olguin
The Court has considered the parties' Joint Statement Regarding Discovery Disputes and the
supporting Declaration of Michael Freiman. Good cause appearing, and in light of the November 5,
2026 close of fact discovery (Dkt. 14), the Comi ORDERS as follows:
1. Written discovery. No later than October 16, 2026, Defendants Walmart Inc. and
Wal-Mart Associates, Inc. shall each (a) serve complete answers to Plaintiff's Interrogatories, Set
One, Nos. 1-21, signed and verified as required by Federal Rule of Civil Procedure 33(b)(3) and (5);
(b) serve amended answers to Plaintiff's Requests for Admission, Set One, Nos. 1-60 that comply
with Rule 36(a)(4), and any request not so answered by that date is deemed admitted; (c) serve
amended responses to Plaintiff's Requests for Production of Documents, Set One, Nos. 1-30 that
comply with Rule 34(b)(2)(B)--(C), and produce all responsive documents and electronically stored
information in its possession, custody, or control; and (d) serve a privilege log that complies with
[PROPOSED] ORDER ON JOINT STATEMENT REGARDING DISCOVERY DISPUTES
Case No. 4:25-cv-08157-AMO
Case 4:25-cv-08157-AMO Document 34 Filed 10/09/26 Page 1 of 2

1 Section 1.5 of the Court's Standing Order for Civil Cases for any document withheld on the basis of
2 privilege or work product. Defendants' objections to these requests,other than objections based on the
3 attorney-client privilege or the work-product doctrine, are OVERRULED.
4 2. R1de 30(b)(6) depositions. No later than October 16, 2026, each Defendant shall identify
5 its designee(s) for each matter for examination in Plaintiff's July 15,2026 notice of deposition under
6 Rule 30(b)(6) and produce the documents requested in Schedule B to that notice. The deposition of
7 Walmart Inc. shall proceed on October 27, 2026, and the deposition of Wal-Mart Associates, Inc.
8 shall proceed on October 28, 2026,each beginning at 9:00 a.m. at Regus - Downtown San Mateo,3
9 East Third Avenue, Suite 200, San Mateo, California 94401, unless the parties agree in writing to
10 other dates no later than October 30,2026.
11 3. Witness depositions. No later than Octoher 13,2026,Defendants shall (a) state, for each
12 of Adam Tanimura, Annie Zhuo, Donnie Tanner, Harvey Ma, LaTonya Foster, Zachary Haas, and
13 Mari Kokka,whether Defendants will produce the witness for deposition or their counsel will accept
14 service of a deposition subpoena on the witness's behalf; (b) provide, for each such witness, a
15 deposition date between October 19 and November 4,2026; and (c) provide the last-known address,
16 telephone number, and e-mail address of Paige Zhang and of each other listed witness who is no
17 longer employed by Defendants.
18 4. Timing. If any date in this Order has passed when the Order is entered,the corresponding
19 deadline is three court days after the date of this Order.
20 IT IS SO ORDERED.
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22 Dated: October 9, 2026
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ARACELI MARTINEZ-OLGUIN
United States District Judge
[PROPOSED] ORDER ON JOINT STATEMENT REGARDING DISCOVERY DISPUTES
Case No. 4:25-cv-08157-AMO
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Case 4:25-cv-08157-AMO Document 34 Filed 10/09/26 Page 2 of 2