Counsel

JOINT STATUS REPORT

Pursuant to Dkt. No. 2432, Plaintiffs and Defendants Uber Technologies, Inc., Rasier, LLC, and Rasier-CA, LLC (collectively, “Defendants”) (jointly, “the parties”), respectfully submit this Joint Stipulation.

I. Production of Requested Hyperlinked Material

With respect to the following categories of material i) hyperlinks to non-Google Drive documents,[1] ii) hyperlinked documents contained within non-Gmail documents, and iii) hyperlinked documents contained within earlier-in-time emails within an email thread, the Parties hereby stipulate as follows:

1. Plaintiffs will be permitted to make one request per week, by Wednesday of each week, until the deadline for substantial completion of fact discovery, for no more than ten (10) hyperlinked documents that have otherwise not been produced, by providing Defendants a list of the specific hyperlinks along with the document Bates number in which each hyperlink appears.

2. In response to these once-weekly requests, Defendants will have five (5) business days to provide the requested hyperlinked documents to Plaintiffs to the extent the requested hyperlinked document is an internal Uber document that “is not privileged or otherwise protected from disclosure,” see ECF No. 2432 at 2, 6, and available to be collected.

3. If Defendants are unable to satisfy or fulfill Plaintiffs’ request(s), the Parties are required to meet-and-confer upon request within 3 business days of Defendants’ deadline to provide the requested hyperlinked documents, and Defendants will provide a written response indicating why they are unable to satisfy or fulfill Plaintiffs’ request(s). If Plaintiffs are unsatisfied by the Defendants’ explanation for why such additional documents cannot be produced, the meetand-confer will qualify as the Parties’ final meet-and-confer for the purposes of PTO 8.

4. The limit of ten (10) hyperlinked documents per week set forth in Paragraph 1 is the compromise to which the parties have agreed for the purpose of completing depositions of Uber’s custodians. Before the deadline for substantial completion of fact discovery, the parties will participate in a meet-and-confer to address any additional reasonable requests for hyperlinked documents in any of the enumerated categories, above the weekly production provided in Paragraph 1 (to the extent Plaintiffs have such requests). To the extent the parties are unable to come to an agreement, any party may address the dispute via PTO 8.

IT IS SO ORDERED.