Plaintiff Eloisa Martinez’s Motion to Compel Further Responses to Requests for Production is GRANTED as to Requests No. No. 6–9, 11–16, 19–25, 27, 28, 30–33, 37–40, 42, 43, 48, 52–56, 58, 59, 64, and 65, subject to the parties’ agreement as to an appropriate opt-out notice procedure for affected employees, and DENIED as to Requests No. 1–5, 10, 17, 18, 26, 29, 34–36, 41, 44–47, 49–51, 57, and 60–63. No sanctions are awarded.

MOTION TO COMPEL— DOCUMENTS

“A propounding party may demand a responding party to produce documents that are in their possession, custody or control. (Code Civ. Proc., § 2031.010.) A party may likewise conduct discovery by propounding interrogatories to another party to be answered under oath. (Code Civ. Proc. § 2030.010, subd. (a).) The responding party must respond to the production demand either by complying, by representing that the party lacks the ability to comply, or by objecting to the demand. (Code Civ. Proc., § 2031.210.) The responding party must respo