![]() B.) 1 After producing some documents and identifying others in its privilege log, Defendant claimed that no other responsive documents were known to exist. In particular, Plaintiff requested, "All documents describing all actions taken by Defendant to ensure that the parking facilities at its store comply with 28 U.S.C. On March 2, 2015, Plaintiff served Defendant with Plaintiff's Amended Second Set of Requests for Production. A.) In pertinent part, Plaintiff requested: "All documents of any nature which reflect Defendant's efforts to cause the Defendant's parking lots and/or paths of travel from the parking lots to the Defendant's facilities to comply with the ADA " and "All documents which reflect Defendant's efforts to ensure the Defendant's facilities comply with the ADA." Defendant served responses to Plaintiff's discovery requests on February 23, 2015. Plaintiff states that, on January 7, 2015, she served her First Set of Requests for Production of Documents on Defendant. 85) and on October 13, 2015, Plaintiff filed a reply brief (ECF No. On October 7, 2015, Defendant filed a response in opposition to the motion (ECF No. ยง 12101 (ADA), as well as other documents relating to ADA compliance that Defendant's 30(b)(6) corporate designee, Steven Dorsey, referred to during his deposition. 76), requesting that Defendant, Cracker Barrel Old Country Store, Inc., be required to produce any and all reports prepared by third parties that assessed Defendant's compliance with the parking accessibility requirements of the Americans With Disabilities Act, 42 U.S.C. On September 23, 2015, Plaintiff, Sarah Heinzl, filed a motion to compel (ECF No. ![]()
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