1

DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

GORDON & POLSCER, LLC

Andrew S. Moses, OSB No. 983009

Email: amoses@gordon-polscer.com

9755 SW Barnes, Suite 650

Portland, Oregon 97225

Telephone: (503) 242-2922

SEYFARTH SHAW LLP

Gerald L. Maatman, Jr.

Email: gmaatman@seyfarth.com

Joshua M. Henderson

Email: jhenderson@seyfarth.com

Michael W. Kopp

Email: mkopp@seyfarth.com

131 South Dearborn Street, Suite 2400

Chicago, Illinois 60603

Telephone: (312) 460-5000

Facsimile: (312) 460-7000

Attorneys for Defendant

KELLY SERVICES, INC.

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

MICHAEL MAKANEOLE, individually and 

on behalf of all similarly situated,

Plaintiff,

v.

SOLARWORLD INDUSTRIES 

AMERICA, INC.; SOLARWORLD 

INDUSTRIES AMERICA, LP; 

SOLARWORLD INDUSTRIES 

SERVICES, LLC; SOLARWORLD 

POWER PROJECTS, INC., RANDSTAD 

PROFESSIONALS US, LP, and KELLY 

SERVICES, INC.,

Defendants.

Case No. 3:14-CV-01528-PK

DEFENDANT KELLY SERVICES, 

INC.’S MOTION TO COMPEL

PLAINTIFF’S FURTHER 

RESPONSES TO REQUESTS FOR 

PRODUCTION

ORAL ARGUMENT REQUESTED

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7-1 and FRCP 37

This Motion is made following the conference of counsel pursuant to Local Rule 7-1, 

which took place by telephone on May 22, 2015, between one of Defendant KSI’s counsel, 

Michael Kopp, and David Schuck, one of the counsel for Plaintiff, for the purpose of meeting 

and conferring regarding the issues address in this motion. Prior to that conference, via 

correspondence on April 14, 2015, and May 19, 2015, Defendant KSI’s counsel, attempted to 

resolve this matter informally without the Court’s intervention, with an identification of the 

specific deficiencies in Plaintiff’s discovery responses, as well as a discussion of the legal basis 

for the need for plaintiff’s supplementation.

Despite these good faith efforts and discussions, the parties were unable to reach any 

agreement regarding the issues raised in the motion.

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 26-3(b)

This brief complies with the applicable word count limitation under Local Rule 26-3(b)

because it contains 2,853 words, including headings, footnotes, and quotations, but excluding the 

caption, signature block, exhibits, and any certificates of counsel.

MOTION

TO THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

AND TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

PLEASE TAKE NOTICE that, Defendants Kelly Services, Inc. (“KSI”), hereby moves

the Court to enter an order compelling Plaintiff to produce documents responsive to KSI’s

Requests for Production, pursuant to the Proposed Stipulated Protective Order attached hereto as 

Exhibit 1.

Pursuant to LR 7-1(c), this Motion is supported by the below Memorandum of Law.

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT KSI’S MOTION TO 

COMPEL.

I. KSI Is Entitled To The Non-Privileged Materials Plaintiff Cites In His Complaint 

As The Factual Basis For His Claims

Although Plaintiff’s Complaint repeatedly references admissions, pleadings, and 

information produced in a pending state court action against the SolarWorld defendants as the 

factual basis for his wage and hour claims in this action, he refuses to produce a single page of 

this non-privileged evidence based on the assertion that he does not have possession, custody, or 

control of it. Federal courts have described this type of objection (i.e., “I don’t have it, my 

attorney does”) as follows: “the objection ‘could scarcely be more frivolous or more pretextual’ 

since documents in the hands of a party’s lawyer are within that party’s possession, custody or 

control.” Jackson v. N’Genuity Enterprises Co., No. 09 C 6010, 2011 WL 4375882 (N.D. Ill. 

Sept. 19, 2011).

KSI is not a party to the pending state court action (Frederick Bey v. SolarWorld 

Industries America, Inc., et. al, Case No. 1212-16562, Multnomah County Circuit Court), and, 

accordingly, has never been served with the pleadings, discovery, depositions, or other materials 

in that action. Nonetheless, the discovery, testimonial admissions, and pleadings in that action 

against SolarWorld—which Plaintiff has asserted are the framework for his claims here—is 

critically important to KSI’s defense of this action, because Plaintiff seeks to impose liability 

upon KSI for Solarworld’s timekeeping practices (at issue in the Bey litigation). Accordingly, 

KSI served discovery requests on Plaintiff requesting that Plaintiff produce the pleadings, 

motions, and discovery, and deposition transcripts from the Bey case that Plaintiff is openly 

citing and relying upon to state and prosecute his claims in this action. Plaintiff has declined to 

produce a single page of this material, on the basis that he does not have documents in his

possession, custody, or control. KSI twice provided plaintiff with a detailed written discussion 

of the uniform body of case law contradicting plaintiff’s position, and sought to resolve the 

dispute informally without the need for court intervention. Yet, Plaintiff continues to withhold 

from KSI all responsive documents to these requests. 

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

For these reasons, and those stated below, the Court should grant KSI’s Motion to 

Compel Plaintiff to produce responsive documents. 

KSI’S DISCOVERY REQUESTS AND PLAINTIFF’S OBJECTIONS

On February 9, 2015, KSI served plaintiff its Request for Production of Documents, Set 

One, to which Plaintiff served its responses on March 13, 2015, and supplemental responses on 

May 22, 2015 (Maatman Decl. ¶3-4, Exs. B and C). Pursuant to Local Rule 37-1 and 26-3, KSI 

identifies the following requests for production for which it seeks responsive documents, with 

plaintiff’s responses and objections. 1

Request No. 33: All DOCUMENTS that RELATE TO YOUR allegations in Paragraph 

40 of the COMPLAINT that “The class is believed to exceed 500 persons . . .”

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that the 

request fails to identify documents with reasonable particularity and is overbroad. Plaintiff 

further objects that the response requires Plaintiff and his attorneys to first make a legal 

conclusion then to provide documents which support that legal conclusion. Subject to and 

without wavier of these objections and the general objections, Plaintiff informs Defendant that 

no such documents are in his possession, custody or control.

Request No. 34: All deposition transcripts from the Frederick Bey v. SolarWorld 

Industries America, Inc. et al., action, Case No. 1212-16562.

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that this 

seeks documents in a case where Plaintiff is not a party and which are outside his possession, 

custody or control.

Request No. 35: All documents produced in the Frederick Bey v. SolarWorld Industries 

America, Inc. et al., action, Case No. 1212-16562.

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that this 

seeks documents in a case where Plaintiff is not a party and which are outside his possession, 

 

1 Because plaintiff has taken the global position as to all of KSI’s requests for production that he 

does not have possession, custody, or control over documents that are held by his attorney, KSI 

seeks supplementation of all of Plaintiff’s responses to KSI’s requests.

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

custody or control.

Request No. 36: All discovery responses served in the Frederick Bey v. SolarWorld 

Industries America, Inc. et al., action, Case No. 1212-16562.

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that this 

seeks documents in a case where Plaintiff is not a party and which are outside his possession,

custody or control.

Request No. 37: All pleadings and motions filed in the Frederick Bey v. SolarWorld 

Industries America, Inc. et al., action, Case No. 1212-16562.

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that this 

seeks documents in a case where Plaintiff is not a party and which are outside his possession, 

custody or control. Further, Defendant has access to these public documents in the Circuit Court 

for the State of Oregon for the County of Multnomah County

Request No. 38: All DOCUMENTS that RELATE TO any COMMUNICATIONS 

between YOU and Frederick Bey regarding this action or the Frederick Bey v. SolarWorld 

Industries America, Inc. et al., action, Case No. 1212-16562.

Plaintiff’s Response: In addition to the general objections, Plaintiff objects in so far as it 

seeks documents not relevant to the claims in the case nor appears reasonably calculated to lead 

to the discovery of admissible evidence in so far as Defendant seeks communications regarding 

the Frederick Bey v. Solarworld Industries America, Inc. et all, action, Case No. 1212-16562. 

Subject to and without wavier of these objections and the general objections, Plaintiff informs 

Defendant that no such documents are in his possession, custody or control.

Request No. 39: All DOCUMENTS that RELATE TO YOUR allegations in Paragraph 

51 of the COMPLAINT that “Plaintiff has a good faith belief that wages are due absent class 

members based in part upon data provided from Employers in other cases”, including but not 

limited to all data provided in the Frederick Bey v. SolarWorld Industries America, Inc. et al., 

action, Case No. 1212-16562.

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that the 

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

request fails to identify documents with reasonable particularity and is overbroad. Plaintiff 

further objects that the response requires Plaintiff and his attorneys to first make a legal 

conclusion then to provide documents which support that legal conclusion. Subject to and 

without waiver of these objections and the general objections, Plaintiff informs Defendant that 

no such documents are in his possession custody or control. 

Request No. 40: All DOCUMENTS that RELATE TO YOUR allegations in Paragraph 

52 of the COMPLAINT that “Plaintiff has a good faith belief that wages are due absent class 

members based on the fact that Defendants have admitted how they programmed their electronic 

time keeping system and further how that system operates with payroll.”

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that the 

request fails to identify documents with reasonable particularity and is overbroad. Plaintiff 

further objects that the response requires Plaintiff and his attorneys to first make a legal 

conclusion then to provide documents which support that legal conclusion. Subject to and 

without waiver of these objections and the general objections, Plaintiff informs Defendant that 

no such documents are in his possession custody or control.

Request No. 41: All DOCUMENTS that RELATE TO YOUR allegations in Paragraph 

53 of the COMPLAINT that “Employers suffered and permitted Plaintiff and similarly situated 

individuals to work hours for which Employers did not compensate them. Employers did so by 

not including all hours worked and recorded on the electronic time keeping system when 

computing employee pay. Employers also did this by altering lunch punches such that the lunch 

was deducted in its entirety or by failing to pay for the interrupted lunch.”

Plaintiff’s Response: In addition to the general objections, Plaintiff objects that the 

request fails to identify documents with reasonable particularity and is overbroad. Plaintiff 

further objects that the response requires Plaintiff and his attorneys to first make a legal 

conclusion then to provide documents which support that legal conclusion. Subject to and 

without waiver of these objections and the general objections, Plaintiff informs Defendant that 

no such documents are in his possession custody or control.

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

ARGUMENT

I. The Requested Discovery is Relevant.

Plaintiff’s complaint repeatedly makes reference to “admissions,” data, and information 

previously provided by the SolarWorld defendants in the Bey litigation, as well as the Bey 

litigation itself. For example:

 Para. 40 alleges: “The class is believed to exceed 500 persons and may increase based on 

the turnover rate of employees during the applicable statute of limitations. Deposition 

testimony confirms that more than 100 class members exist . . .”

 Para. 51 alleges: “Plaintiff has a good faith belief that wages are due absent class 

members based in part upon data provided from Employers in other cases”

 Para. 52 alleges: “Plaintiff has a good faith belief that wages are due absent class 

members based on the fact that Defendants have admitted how they programmed their 

time keeping system and further how that system operates with payroll.

Paras. 70, 93 and 108 allege: For the SolarWorld defendants “this claim runs from the 

date of filing back to the date Frederick Bey’s case was filed in Multnomah County

The Complaint makes further reference to other specific programming features and data 

that appear to have been obtained in the Bey discovery. See, e.g., Para. 74 (“Employers Kronos 

time keeping system downloaded data to Etime computer program.” [sic]) 

These materials—expressly incorporated in Plaintiff’s complaint as the source of the 

Plaintiff’s “good faith belief” for his allegations as to liability and class composition—are 

unquestionably relevant, and KSI is entitled to their production. See generally, Fed. R. Civ. P. 

26(b)(1) (“Parties may obtain discovery regarding any non-privileged matter that is relevant to 

any party’s claim or defense—including the existence, description, nature, custody, condition, 

and location of any document or other tangible things and the identify and location of persons 

having knowledge of any discoverable matter.”); Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 

340, 351 (1978) (The relevant standard is broad in order “to encompass any matter that bears on, 

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

or that reasonably could lead to other matter that could bear on, any issue that is or may be in the 

case.”)

II. Plaintiff May Not Withhold Non-Privileged Documents Held By His Attorney

Plaintiff takes the position that he does not have custody, possession, or control of

documents that are admittedly in his attorneys’ possession, and is thereby not obligated to 

produce them. That position is not only incorrect—but has been aptly described as “frivolous.” 

See, e.g., Jackson v. N’Genuity Enterprises Co., No. 09 C 6010, 2011 WL 4375882 (N.D. Ill. 

Sept. 19, 2011) (“defendants objected to production on the ground that they did not have 

possession of the documents, which were in the possession of their lawyers . . . the objection 

‘could scarcely be more frivolous or more pretextual’ since documents in the hands of a party’s 

lawyer are within that party’s possession, custody or control.”); Axler v. Scientific Ecology 

Group, Inc., 196 F.R.D. 210, 212 (D. Mass. 2000) (“Similarly, a party must produce otherwise 

discoverable documents that are in his attorneys’ possession, custody or control.”); accord, Hill 

v. Asset Acceptance, LLC, No. 13-CV-1718-BEN (BLM), 2014 WL 3014945 (S.D. Cal. July 3, 

2014); Hammond v. Management & Training Corp., No. 1:13-cv-1209-AWI-JLT, 2015 WL 

402022 (E.D. Cal. Jan. 29, 2015); In re Papst Licensing GmbH Patent Litigation, No. Civ. A 99-

MD-1298 (E.D. La. July 12, 2001) (collecting cases). 

III. Plaintiff’s Remaining Objections Are Without Merit

A. Plaintiff’s Belated “Ethical Obligation Objection” Was Never Raised and Is 

Without Merit

In the parties’ meet and confer correspondence, Plaintiff made reference to an “ethical 

obligation to another client in another case,” as an additional basis for withholding the requested 

Bey materials. (Maatman Decl. ¶E.) Plaintiff did not raise privilege as a grounds for 

withholding the documents in the parties’ telephonic meet and confer (and KSI made clear 

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

during that conference it is not seeking attorney-client privileged documents). Nonetheless, to 

the extent Plaintiff raises “privilege” as an argument in opposition, it would in no way supports 

plaintiff’s withholding of responsive documents. First, such an objection was not asserted in 

plaintiff’s responses to Requests for Production Nos. 33-41, and is thereby waived. Second, 

plaintiff produced no privilege log, also thereby waiving the privilege. Third, such an objection 

could not apply, as these requests do not call for attorney-client privileged material. 

Instead, the requests call for documents such as deposition transcripts, produced 

documents, discovery responses, and pleadings and motions from the Bey action, as well as 

documents related to plaintiff’s assertion that “Plaintiff has a good faith belief that wages are due 

absent class members based in part upon data provided from Employers in other cases.” See, 

Request No. 39. There is no explanation offered, nor is any credible explanation possible, as to 

how the above documents would be privileged or violate an ethical obligation owed to another 

client. Moreover, Plaintiff has placed these documents at issue. Indeed, plaintiff repeatedly 

refers to the Bey documents as underpinning his factual assertions in his Complaint. In sum, 

plaintiff may not rely upon an “ethical obligation” “objection” that was never asserted, as to 

documents which categorically fall outside of any attorney client privilege (and which plaintiff’s 

complaint puts at issue), to withhold these responsive documents.

B. General Objections Do Not Permit Plaintiff To Withhold Documents.

Plaintiff’s boilerplate reference to “general objections” is not a proper basis for 

withholding the requested materials, data, and documents from the Bey litigation. Midwest 

Investment Partners, LLC v. Gerriets, No. 3:14-cv-40-RLY-WGH, 2015 WL 1526087 (S.D. Ind. 

April 3, 2015) (General objections “whether placed in a separate section or repeated by rote in 

response to each requested category, are not ‘objections’ at all—and will not be considered.’”); 

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

accord Mills v. E. Gulf Coal Preparation Co., LLC, 259 F.R.D. 118, 132 (S.D.W. Va. 2009); 

Sabol v. Brooks, 469 F.Supp. 2d 324, 328-29 (D. Md. 2006). 

C. A “Legal Conclusion” Objection Does Not Permit Plaintiff To Withhold 

Documents.

As to certain requests for Bey materials, Plaintiff objects that the “response requires 

Plaintiff and his attorneys to first make a legal conclusion then to provide documents which 

support that legal conclusion.” Such an objection is baseless. First, the requests in no way seek 

legal conclusions, but rather documents supporting Plaintiff’s allegations. For example, RFP No. 

39 seeks all documents that relate to the allegation in Paragraph 59 of the Complaint that 

“Plaintiff has a good faith belief that wages are due absent class members based in part upon 

data provided from Employers in other cases.” This request simply asks plaintiff to produce 

this non-privileged data that Plaintiff is specifically identifying as underpinning his core liability 

allegations.2Second, such an objection cannot support withholding responsive documents. See, 

e.g., Sonnino v. University Kansas Hosp. Auth., 220 F.R.D. 633, 643 (D. Kan. 2004) (“That a 

discovery request “calls for a legal conclusion” is not valid objection.”).

D. The “Publicly available” Objection Does Not Permit Plaintiff to Withhold 

Documents.

Plaintiff also objects to the request for all pleadings and motions filed in the Bey action 

on the ground that the documents are publicly available. That objection is improper, and cannot 

support withholding responsive documents. Hill v. Asset Acceptance, LLC, No. 13-CV-1718-

BEN (BLM), 2014 WL 3014945 (S.D. Cal. July 3, 2014) (holding that party’s objection that “the 

court records are publicly available to Plaintiff” is not a proper objection to discovery request); 

 

2

For the same reason, plaintiff’s objection that the request lacks sufficient “particularity” is without 

merit. Plaintiff has referenced these materials in his Complaint. To the extent there was any confusion, 

KSI has made clear it seeks the pleadings, motions, discovery responses and productions and depositions 

in the Bey v. Solarworld action. 

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DEFENDANT KELLY SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S 

FURTHER RESPONSES TO REQUESTS FOR PRODUCTION

Thomas v. Hickman, 2007 WL 4302974 at *19 (E.D. Cal. Dec. 6, 2007) (holding that “the fact 

that some of the documents might be possessed by Plaintiff or be available to Plaintiff or the 

public is not a basis for refusing to produce documents that are otherwise discoverable.”), citing 

6 James Wm. Moore et al., MOORE’S FEDERAL PRACTICE § 26.41[13] 3d ed. 2006 and 

Weiner v. Bache Halsey Stuart, Inc., 76 F.R.D. 624, 625 (S.D. Fla. 1977)); see also Bretana v. 

International Collection Corp., 2008 WL 4334710, *5–6 (N.D. Cal. Sept. 22, 2008) (stating that 

defendant cannot validly object to producing discovery because the information is contained in 

public records available to all parties), citing St. Paul Reinsurance Co., Ltd. v. Commercial Fin. 

Corp., 198 F.R.D. 508, 514 (N.D. Iowa 2000) (“It is ‘not usually a ground for objection that the 

information is equally available to the interrogator or is a matter of public record.’”). 

CONCLUSION

For all of the foregoing reasons, KSI respectfully requests that the Court compel the 

Plaintiff to further respond to all of KSI’s Requests for Production, to produce non-privileged 

Bey litigation materials in plaintiff’s and his attorney’s possession, to provide supplemented 

responses to KSI’s requests for production and to specifically produce materials responsive to 

Request Nos. 33-41. 

DATED this 3rd day of June, 2015.

By: /s/ Andrew S. Moses

Andrew S. Moses

amoses@gordon-polscer.com

Gordon & Polscer, L.L.C.

(503) 242-2922

By: /s/ Gerald L. Maatman, Jr.

Gerald L. Maatman, Jr.

Joshua M. Henderson

Michael W. Kopp

Seyfarth Shaw LLP

Attorneys for Defendant Kelly Services, Inc.

Case 3:14-cv-01528-JR Document 61 Filed 06/03/15 Page 11 of 13
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CERTIFICATE OF SERVICE

CERTIFICATE OF SERVICE

I certify that on the date indicated below, I filed the foregoing DEFENDANT KELLY 

SERVICES, INC.’S MOTION TO COMPEL PLAINTIFF’S FURTHER RESPONSES TO 

REQUESTS FOR PRODUCTION with the Clerk of the Court using the CM/ECF e-filing 

system, which will electronically serve said filing on:

David A. Schuck

dschuck@wageclaim.org

Stephanie J. Brown

sbrown@wageclaim.org

Karen A. Moore

kmoore@wageclaim.org

SCHUCK LAW, LLC

Attorneys at Law

10013 NE Hazel Dell Avenue #178

Vancouver, WA 98685

Phone: (360) 566-9243

Fax: (503) 575-2763

Attorney for Plaintiff

Victor J. Kisch

vjkisch@stoel.com

Todd A. Hanchett

tahanchett@stoel.com

John B. Dudrey

jbdudrey@stoel.com

STOEL RIVES LLP

900 SW Fifth Avenue, Suite 2600

Portland, OR 97204

Phone: (503) 224-3380

Fax: (503) 220-2480

Attorneys for Defendant Solarworld

/ / /

/ / /

/ / /

/ / /

Case 3:14-cv-01528-JR Document 61 Filed 06/03/15 Page 12 of 13
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CERTIFICATE OF SERVICE

Clarence M. Belnavis

cbelnavis@laborlawyers.com

FISHER & PHILLIPS LLP

111 SW Fifth Avenue, Suite 4040

Portland, Oregon 97204

Phone: (503) 242-4262 

Fax: (503) 242-4263

John S. Snelling (admitted pro hac vice)

john.snelling@lewisbrisbois.com

Toni J. Read (admitted pro hac vice)

toni.read@lewisbrisbois.com

LEWIS BRISBOIS BISGAARD & SMITH, LLP

1180 Peachtree Street, NE, Suite 2900

Atlanta, GA 30309

Phone: (404) 348-8585

Fax: (404) 467-8845 

Attorneys for Defendant Randstad

DATED this 3rd day of June, 2015.

By: /s/ Andrew S. Moses

Andrew S. Moses

amoses@gordon-polscer.com

Gordon & Polscer, L.L.C.

(503) 242-2922

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