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UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF MICHIGAN

BRYAN ROBBINS, on behalf of 

himself, all others similarly situated, 

and the general public,

Plaintiffs,

v.

THE COCA-COLA COMPANY, a 

Delaware Corporation,

Defendant.

Miscellaneous Case

Case No.: 2:14-mc-50538-MFL-DRG

Lead Case Pending in the

Southern District of California

Civil Action No.: 3:13-cv-00132-JLSWVG

JOINT STATUS REPORT 

REGARDING PLAINTIFF’S

MOTION TO ENFORCE 

SUBPOENAS ON 

HELLOWORLD, INC.

Plaintiff Bryan Robbins, Defendant The Coca-Cola Company (“Coca-Cola” 

or Defendant”) and third party HelloWorld, Inc (“HelloWorld”), through 

undersigned counsel, respectfully submit the following Joint Status Report 

Regarding Plaintiff’s Motion to Enforce Subpoenas on HelloWorld, Inc. 

On May 20, 2014, this Court held a telephone status conference regarding 

Plaintiff’s Motion to Enforce Subpoenas on HelloWorld, Inc. in front of the 

Honorable Avern Cohn. During the conference this Court ordered that HelloWorld 

conduct a reasonable search of its record for the number of Plaintiff Bryan 

Robbins. Additionally, the Court provided that Plaintiff may conduct a Fed. Rule 

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of Civ. Proc. 30(b)(6) deposition in regard to HelloWorld’s search. This Court 

provided the parties with a deadline of one month. 

On June 11, 2014, the Southern District of California issued an order in the 

lead case, Robbins v. Coca-Cola Company, 13-CV-0132-JLS (WVG) (“Robbins”), 

stating, “[a]s ordered by the Eastern District of Michigan, all remaining discovery 

from HelloWorld shall be produced by June 19, 2014, and the deposition of 

HelloWorld’s Rule 30(b)(6) witness must be completed on or before June 19, 

2014.” See Robbins Dkt. No. 65. 

In compliance with this Court’s order, on June 13, 2014, HelloWorld 

provided Plaintiff’s counsel with 1) an Affidavit of Sagar Parvataneni, which 

purported to reflect the results of the search of the incoming and outgoing calls

related to the phone number of Plaintiff and Plaintiff himself, 2) a copy of the 

Master Services Agreement between HelloWorld, Inc. and Coca-Cola that has 

been in effect since January, 2011, and 3) a copy of the retention policies of 

HelloWorld, Inc. that have been in effect since January, 2011. On June 16, 2014, 

Plaintiff conducted a Fed. R. Civ. Proc. 30(b)(6) deposition and deposed Sagar 

Parvataneni in regard to his search and affidavit. No further issues remain. 

Dated: June 30, 2014 Respectfully submitted,

By: /s/ Perrin Rynders

Perrin Rynders (P38221)

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Varnum

Business Address, Telephone, and E-mail

P.O. Box 352

Grand Rapids, MI 49501-0352

(616) 336-6000

prynders@varnumlaw.com

John W. Barrett

Bailey & Glasser, LLP

209 Capitol Street

Charleston, QV 25301

(304) 345-6555

jbarrett@baileyglasser.com

Co-Counsel for Plaintiff and the Proposed Class

Dated: June 30, 2014 By: /s/ Abraham Singer

Kitch, Drutchas

One Woodard Avenue, 24th Flr

Detroit, Michigan 48226

(313) 965-7900

Abraham.Singer@kitch.com

Counsel for Third-Party HelloWorld, Inc.

Dated: June 30, 2014 By: /s/ Stewart Haskins

King & Spalding

1180 Peachtree Street, NE

Atlanta, Georgia 30309

(404) 572-4600

SHaskins@KSLAW.com

Counsel for Defendant 

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