SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT

ALEXANDRA BRUNELL, Plaintiff, vs. UBER TECHNOLOGIES, INC., et al. Defendants.

CASE NO: BC699297

[TENTATIVE] ORDER GRANTING MOTION TO COMPEL DEPOSITION OF PMK; GRANTING MOTION TO COMPEL DEPOSITION OF TRACEY BREEDEN; DENYING MOTION TO COMPEL PRODUCTION OF DOCUMENTS

Dept. 31

1:30 P.M.

February 13, 2020

Plaintiff served a Notice of Deposition on Defendant Uber Technologies, Inc. (“Uber”) on October 3, 2019. The Notice indicated an intent to depose Tracey Breeden – Uber’s Head of Women's Safety & Gender-based Violence Programs. It was noticed for October 21, 2019. Plaintiff received Defendant’s objection on October 17, 2019. Defendant’s objections include: 1) Ms. Breeden is an apex employee, 2) Plaintiff noticed the deposition for a date prior to an already scheduled deposition of Plaintiff without the agreement of opposing counsel, and 3) a variety of boilerplate and procedural grounds.

Plai