This is an action under the Labor Code, the Private Attorneys General Act (“PAGA”), the Unfair Competition Law (“UCL”), and other statutes. Plaintiff alleges that Defendants Google LLC, Google Inc., and Alphabet, Inc.’s (collectively, “Google”) recruit diverse candidates by misrepresenting the nature of the job they will perform if they are hired; impose unlawful confidentiality agreements and other policies on employees; and retaliate against employees. Plaintiff also brings a range of individual claims arising from his employment with Google.

Before the Court are four motions to compel discovery by Plaintiff, which Google opposes. As discussed below, the motions are GRANTED IN PART and DENIED IN PART.

I. BACKGROUND

A. Factual

According to the operative complaint, plaintiff had a successful career in Illinois as the former chief executive officer of a family business that served as the first minority supplier to Caterpillar, Inc., and then as a Caterpillar employee from the mid-20