[Defendant] currently has close to 27,000 employee files stored at its corporate campus. Personnel files with separation dates two years from the current employment year are stored off-site. The files are sorted alphabetically by employee name. Records for all employees in all states are retained together. [ ] 3. To gather any records of discipline would require a review of every employee file.... In my estimation, it would take at least 20 minutes to locate and review each employee's file, which would result in an estimated total of 600 man-hours to locate and review 1,800 employee files. [ ] 5.... For each employee wage statement retrieved and printed, approximately 5 minutes of time is required.... [T]here have been approximately 1,800 Eddie Bauer employees in California since May 2005.... [I]n each year of work, an employee receives 26 wage statements. Therefore, to print a single year of wage statements for each of the 1,800 employees would require approximately 3,900 hours of work, the equivalent of two years of work.
To generate documentation that reflect[s] each reimbursement to each employee, the first step would be to run a computer-based report to identify which employees received reimbursements in the first place. This step provides a list of the individuals for whom records exist. [ ] 4. The next step would be to search on the accounting system for reimbursement reports for each employee who has a record.... [ ] 5. If there are multiple reimbursement reports for an employee, each reimbursement report file must be opened and viewed separately, one at a time.... [ ] 6. To gather all reimbursements made to employees in California between May 2005 and the present would require approximately 24 man-hours, three full dedicated work days.
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