UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

MARK HANSEN, and JASON BUFFER 

individually and on behalf of all others 

similarly situated,

Plaintiffs,

v.

UNITED AIRLINES, INC.,

Defendant.

Case No. 1:20-cv-02142

Hon. Thomas M. Durkin

Magistrate Judge Jeffrey T. Gilbert

EIGHTEENTH JOINT REPORT ON THE STATUS OF DISCOVERY

Pursuant to the Court’s May 18, 2023 Order (ECF 164), Plaintiffs Mark Hansen and Jason 

Buffer (“Plaintiffs”) and Defendant United Airlines, Inc. (“Defendant” or “United”) submit this 

eighteenth joint report on the status of discovery.

I. Production of ESI and Other Documents.

On September 13, 2022, the Court held a hearing and issued an Order granting in part 

Plaintiffs’ Motion to Compel Discovery (ECF 140). Since then, United has made three productions 

of documents, with its final production occurring on January 18, 2023. Per the Court’s Order of 

September 27, 2022 (ECF No. 142), fact discovery closed on March 28, 2023.

II. Progress on Depositions.

The parties completed the depositions of both Plaintiffs Buffer and Hansen, on 

June 10, 2022, and June 17, 2022, respectively. With respect to United’s depositions, on April 27, 

2022, Plaintiffs served United with a Notice of 30(b)(6) Deposition Notice. United served 

objections to the Notice on Plaintiffs’ counsel on May 16, 2022. The parties subsequently met and 

conferred regarding those objections on June 27, 2022, and resolved those objections before the 

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depositions. The parties have since completed United’s Rule 30(b)(6) depositions. The first such 

deposition took place on December 2, 2022, the second on December 19, 2022, and the third on 

January 12, 2023.

As the parties explained in their Joint Motion to Modify the Case Management Schedule 

(ECF 155), following the completion of the Rule 30(b)(6) depositions and United’s final 

production, the parties met and conferred. At that time, Plaintiffs indicated that they might seek 

additional narrow and targeted depositions of certain fact witnesses. On January 27, 2023, 

Plaintiffs served two such deposition notices, for United employees Mina Taheri and Stephanie 

Sito. United objected that a deposition of Ms. Taheri would be duplicative and cumulative, and 

requested a meet-and-confer call to discuss the issue. The parties met and conferred about the 

deposition notices on February 8, 2023, and agreed that Plaintiffs would first take the deposition 

of Ms. Sito, who is Ms. Taheri’s supervisor, and then consider whether they needed to depose Ms. 

Taheri. The deposition of Ms. Sito took place on March 17, 2023, and Plaintiffs subsequently 

agreed to withdraw their deposition notice to Ms. Taheri. Separately, on February 10, 2023, 

Plaintiffs also noticed the deposition of United employee Annalei Avancena. That deposition took 

place on March 14, 2023. Per the Court’s Order of September 27, 2022 (ECF No. 142), fact 

discovery closed on March 28, 2023.

III. Rule 26(a)(2) Disclosures and Expert Depositions.

In accordance with the Court’s January 27, 2023 Order (ECF 156), the parties exchanged

their Rule 26(a)(2) disclosures on April 20, 2023 and rebuttal reports on May 22, 2023. Plaintiffs 

deposed United’s expert on June 1, 2023, and United deposed Plaintiffs’ expert on June 6, 2023.

IV. Proposed Date for Next Joint Report on the Status of Discovery.

Per the Court’s Orders of September 27, 2022 (ECF 142) and January 27, 2023 (ECF 156), 

both fact and expert discovery are now closed. The parties defer to the Court on whether, given 

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that circumstance, the Court would like the parties to file any further joint reports on the status of 

discovery.

Dated: June 12, 2023 Respectfully submitted,

By: Daniel J. Kurowski

Steve W. Berman

HAGENS BERMAN SOBOL SHAPIRO LLP

1301 Second Avenue, Suite 2000

Seattle, WA 98101

(206) 623-7292

steve@hbsslaw.com

Daniel J. Kurowski

Whitney K. Siehl

HAGENS BERMAN SOBOL SHAPIRO LLP

455 N. Cityfront Plaza Dr., Suite 2410

Chicago, IL 60611

(708) 628-4949

dank@hbsslaw.com

whitneys@hbsslaw.com

Interim Co-Lead Counsel

By: Nickolas J. Hagman

Daniel O. Herrera 

Nickolas J. Hagman 

CAFFERTY CLOBES MERIWETHER &

SPRENGEL LLP

135 S. LaSalle Street, Suite 3210

Chicago, Illinois 60603

T: (312) 782-4880 

F: (318) 782-4485 

dherrera@caffertyclobes.com 

nhagman@caffertyclobes.com 

Bryan L. Clobes

CAFFERTY CLOBES MERIWETHER &

SPRENGEL LLP

205 N. Monroe St. 

Media, Pennsylvania 19063 

T: (215) 864-2800 

bclobes@caffertyclobes.com

Interim Co-Lead Counsel

withJoseph G. Sauder

Joseph B. Kenney

SAUDER SCHELKOPF LLC

1109 Lancaster Ave.

Berwyn, PA 19312

Telephone: (888)-711-9975

Facsimile: (610) 421-1326

jgs@sstriallawyers.com

jbk@sstriallawyers.com

Additional Counsel for Plaintiffs

By: Sondra A. Hemeryck

Patricia Brown Holmes

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Sondra A. Hemeryck

Eli J. Litoff

Brendan J. Gerdes

RILEY SAFER HOLMES & CANCILA LLP

70 W. Madison St., Suite 2900

(312) 471-8700

pholmes@rshc-law.com

shemeryck@rsch-law.com

elitoff@rsch-law.com

bgerdes@rshc-law.com

Counsel for United Airlines, Inc.

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