eDiscovery Assistant

In re Uber Techs., Inc. Passenger Sexual Assault Litig.

Case No. 23-md-03084 (N.D. Cal. 2024)

January 13, 2025

Cisneros, Lisa J., United States Magistrate Judge

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Summary

The parties have reached an agreement on all issues related to the production of data by the defendants regarding their U.S. Safety Reports. The defendants will produce a reproduction of all data, including newly-produced and previously-produced data, and will also provide all files and data attached to Jira and Bliss tickets for up to 375 safety incidents chosen by the plaintiffs. The plaintiffs reserve their right to raise any further access or functionality issues with the court if they are unable to resolve them with the defendants.

Additional Decisions

IN RE: UBER TECHNOLOGIES, INC., PASSENGER SEXUAL ASSAULT LITIGATION
This Document Relates to: ALL ACTIONS

Case No.: 3:23-md-03084 CRB

United States District Court, N.D. California

Filed January 13, 2025

Cisneros, Lisa J., United States Magistrate Judge

JOINT LETTER REGARDING PLAINTIFFS’ REQUEST FOR PRODUCTION OF U.S. SAFETY REPORT DATA (CORRECTED)

Joint Statement

Pursuant to the Court’s December 19, 2024 and December 24, 2024 Orders (ECF Nos. 1996 and 2016), the parties respectfully submit this joint discovery letter regarding disputes related to Defendants’ production of data related to its U.S. Safety Reports. The parties have reached an agreement on all issues related to Defendants’ production of safety data currently pending before the Court.

A. Access and Functionality Issues

As of the time of this filing, all known access and functionality issues have been resolved.[1] Defendants will produce the data addressed in the parties’ December 23, 2024 agreement as a reproduction that includes all newly-produced data as well as all previously-produced data, rather than a supplemental production that includes only the newly-produced data.

B. Attachments

The parties agree that Defendants will produce all files and data attached to Jira and Bliss tickets for up to 375 safety incidents of Plaintiffs’ choosing.[2] The files and data will be produced pursuant to the following schedule:

1. Plaintiffs will identify their first selection of 125 incidents by January 24, 2025.[3]
2. Plaintiffs will identify their second selection of 125 incidents by January 31, 2025.
3. Defendants will begin rolling productions by February 14, 2025.
4. Plaintiffs will identify their final selection of 125 incident reports by February 14, 2025.
5. Defendants will complete productions by March 14, 2025.

IT IS SO ORDERED.

Dated: January 13, 2025

Footnotes

[1]

Plaintiffs cannot be certain that no further access or functionality difficulties will arise as additional data is produced and as Plaintiffs’ experts continue to analyze the data. Although the parties will endeavor to work cooperatively to resolve any additional difficulties, Plaintiffs reserve their right to raise any further or amplified access or functionality issues that may arise with the Court if the parties are unable to timely resolve those issues.

[2]

Plaintiffs may select from incidents that were reported to have occurred between January 1, 2017 and December 31, 2022.

[3]

The dates herein are contingent upon Defendants’ complete production of incident data by January 17, 2025 pursuant to the parties’ December 23, 2024 agreement (ECF No. 2011).