Motion to Compel Further Responses to Request for Production of Documents by Defendant Cisco Systems, Inc.

Factual and Procedural Background

This employment action for discrimination based on age, race, national origin, and religion arises out of the refusal by defendant Cisco Systems, Inc. (“Cisco”) to hire plaintiff Syed Nazim Ali (self-represented) (“Ali”).

On April 3, 2017, Ali applied for the following positions with Cisco: (1) Senior Security Consultant; (2) VPN Security Technical Support Engineer; (3) Hybrid Cloud Consultant; (4) Security Consulting Systems/Sales Engineer; (5) IT Auditor Engineer; (6) Security and Compliance Analyst; and (7) Corporate System Engineer. (First Amended Complaint [“FAC”] at ¶¶ 48-55, 87.) Despite Ali’s qualifications for the positions, defendant Cisco did not hire him. (Id. at ¶¶ 49-55, 57-58, 60, 87.) Ali alleges defendant Cisco discriminated and retaliated against him because of his race, religion, and national origin. (Id. at ¶¶ 60, 75, 77, 78