SUBJECT: Motion for Protective Order

Moving Party: Defendants Staples, Inc. and Staples Contract & Commercial, LLC

Resp. Party: Plaintiff Joyce Allen

The Court orders the parties to meet and confer regarding these special interrogatories and then schedule an informal discovery conference with the Court if necessary.

BACKGROUND:

On March 11, 2019, Plaintiff Joyce Allen commenced this action against Defendants Staples, Inc., Staples Contract & Commercial, LLC, Jeffrey Roman Narlock, and Charisse Clay for (1) Equal Pay Act violation; (2) discrimination based on gender; (3) unlawful sexual harassment in violation of FEHA; (4) failure to prevent discrimination and retaliation; (5) retaliation; (6) sexual assault and battery; and (7) wrongful termination in violation of public policy.

Plaintiff alleges that when she was promoted to a Field Sales Director, Defendants did not treat her the same as the other male Field Sales Directors and compensated her less than similarly situated males