EXHIBIT B

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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

DAWON WORDLAW, on behalf of herself

and all others similarly situated,

Plaintiffs,

v.

ENTERPRISE LEASING COMPANY OF 

CHICAGO, LLC; ENTERPRISE HOLDINGS, 

INC.,

Defendants.

Case No. 20-cv-03200

Honorable Manish S. Shah

Honorable Magistrate Gabriel A. Fuentes

DEFENDANT ENTERPRISE LEASING COMPANY OF CHICAGO LLC’S 

RESPONSES TO PLAINTIFF’S FIRST REQUESTS FOR PRODUCTION

Defendant ENTEPRISE LEASING COMPANY OF CHICAGO, LLC (“ENTERPRISE 

LEASING” or “Defendant”), by and through its attorneys, hereby provides its responses to 

Plaintiff Dawon Wordlaw’s (“Plaintiff”) First Set of Requests for Production. 

PRELIMINARY STATEMENT/RESERVATION OF RIGHTS

ENTERPRISE LEASING makes these objections and responses to the Requests 

expressly reserving and without waiver of the following: (a) all rights to object on the basis of 

competency, relevance, materiality, confidentiality, authenticity, privilege, or any other proper 

grounds to the use of any of ENTERPRISE LEASING’s responses or objections to the Requests, 

any information contained therein, or any documents produced in response to the Requests, as 

evidence, in whole or in part, in any subsequent proceeding, action, or matter, or in any trial in

this or any other action; (b) all rights to object on any ground and at any time to a demand or 

request for further response to the Requests, other discovery requests, or proceedings involving 

or related to the subject matter of the Requests or documents ENTERPRISE LEASING has 

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provided or may provide in response to the Requests; and (c) the right at any time to review, 

revise, correct, add to, supplement, amend, or clarify any of the responses propounded herein.

ENTERPRISE LEASING has not yet completed its discovery and investigation of the 

facts pertaining to the above-captioned action (the “Action”), review of its own documents, or 

trial preparation. ENTERPRISE LEASING bases its responses and objections on information 

now known to ENTERPRISE LEASING. ENTERPRISE LEASING reserves the right to rely on 

any facts or other evidence that may develop or come to its attention at a later date.

OBJECTIONS TO ALL REQUESTS

1. ENTERPRISE LEASING objects to the Requests to the extent that they imply or 

assume that ENTERPRISE LEASING was collecting, capturing, processing, using, possessing, 

coming into possession of, storing, distributing, selling, or disclosing biometric information or 

data. ENTERPRISE LEASING denies that it has, at any time, collected, captured, processed, 

used, possessed, come into possession of, stored, distributed, sold, or disclosed the biometric 

information or data of any individual. 

OBJECTIONS TO DEFINITIONS AND INSTRUCTIONS

 

1. ENTERPRISE LEASING objects to the Requests to the extent they seek work 

product, trial preparation materials, identification of documents prepared after the 

commencement of this litigation, communications protected from disclosure by the attorneyclient privilege, or documents protected from disclosure by any applicable law, rule, privilege or 

immunity. Nothing contained in these Responses is intended to or may be construed as a waiver 

of the attorney-client privilege, the work product doctrine, or any other applicable law, rule, or 

privilege. 

2. ENTERPRISE LEASING objects to Plaintiffs’ definition of “Relevant Time 

Period” as overly broad, unduly burdensome, or oppressive to the extent it covers a time period 

beyond the operative statute of limitations for Plaintiffs’ claims, which is one year. Accordingly, 

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ENTERPRISE LEASING has limited its responses to information and documents relative to the 

time period spanning back to one year prior to the filing date. 

3. Each and every answer is made subject to the foregoing general objections and to 

any protective order entered by the Court, regardless of whether a general or specific objection is 

stated in the answer to the particular Interrogatory, and ENTERPRISE LEASING does not waive 

any general objections not referred to in any particular answer. 

4. ENTERPRISE LEASING reserves the right to supplement its Responses with 

information or documents that come to its attention or become available after service of these 

Responses and to use such information at any hearing or proceeding, including the trial of this or 

any other action.

REQUESTS FOR PRODUCTION OF DOCUMENTS

REQUEST NO. 1: All Documents, Including all Data, identified, referenced, or 

contemplated in Your answers to Plaintiff’s Interrogatories, or otherwise relied upon in 

answering Plaintiff’s Interrogatories.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the ground that it is overly broad, 

vague, and ambiguous, premature, duplicative, and seeks information that is neither relevant to 

any party’s claim or defense nor proportional to the needs of the case. ENTERPRISE LEASING

further objects to the phrase “identified, referenced, or contemplated,” as overly broad, vague, 

and ambiguous. Subject to and without waiving the foregoing objections, and subject to this 

request being narrowed to an agreeable scope, ENTERPRISE LEASING will produce responsive 

documents to the extent that such information is within its possession, custody, or control. 

Subject to and without waiving its objections, ENTERPRISE LEASING is willing to 

meet and confer with Plaintiff in an attempt to narrow this Request and will seasonably 

supplement their document production in accordance with the Federal Rules and upon agreement 

between the parties.

REQUEST NO. 2: All Documents, Including Correspondence, regarding, concerning, 

or in any way Related To data privacy and protection, cybersecurity, biometric privacy, the 

Illinois Biometric Information Privacy Act, Your Biometric handling practices, Your handling of 

Biometrics, or Your handling of personal data, or data pertaining to or derived from individuals, 

generally.

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RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. ENTERPRISE 

LEASING objects to Plaintiffs’ use of the words and phrases “data privacy and protection, 

cybersecurity, biometric privacy, the Illinois Biometric Information Privacy Act, Your Biometric 

handling practices, Your handling of Biometric” to the extent they call for a legal conclusion and 

on the grounds that they are undefined, vague, and ambiguous. Further, ENTERPRISE 

LEASING further objects to this Request on the basis that it seeks information on matters that 

are not stated with the requisite reasonable particularity, is unlimited in temporal or geographic

scope, and seeks information outside the relevant statute of limitations. ENTERPRISE 

LEASING objects to this Request on the grounds that it is overbroad, vague, and ambiguous, and 

seeks information that is neither relevant to any party’s claim or defense nor proportional to the 

needs of the case. ENTERPRISE LEASING also objects that this Request seeks confidential 

and/or proprietary information. 

Subject to and without waiving its general and specific objections, ENTERPRISE 

LEASING refers Plaintiff to all documents that will be produced in response to Plaintiff’s First

Request for Production of Documents upon entry of a protective order.

REQUEST NO. 3: All Documents, including all Data, Relating To the provisioning of 

any service, including payroll processing services, to You by Any Third Party, during the 

Relevant Time Period.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. ENTERPRISE 

LEASING further objects to the extent this request seeks documents that are not in its 

possession, but instead possessed by third-parties. ENTERPRISE LEASING objects to 

Plaintiffs’ use of the words and phrases “provisioning of any service” to the extent they call for a 

legal conclusion and on the grounds that they are undefined, vague, and ambiguous. Further, 

ENTERPRISE LEASING further objects to this Request on the basis that it seeks information on 

matters that are not stated with the requisite reasonable particularity, is unlimited in temporal or 

geographic scope, and seeks information outside the relevant statute of limitations. 

ENTERPRISE LEASING objects to this Request on the grounds that it is overbroad, vague, and 

ambiguous, and seeks information that is neither relevant to any party’s claim or defense nor 

proportional to the needs of the case. ENTERPRISE LEASING objects to this Request to the 

extent it seeks confidential information concerning individuals who are not a party to this 

lawsuit. ENTERPRISE LEASING also objects that this Request seeks confidential and/or 

proprietary information. 

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On the basis of the foregoing objections, ENTERPRISE LEASING is withholding 

documents responsive to this Request. To the extent Plaintiff narrows or clarifies this Request, 

ENTERPRISE LEASING may reconsider its Response. 

REQUEST NO. 4: All Documents, Including all Data, Relating to any agreement, 

whether in writing or otherwise, between You and Any Third Party or vendor relating to 

biometric timekeeping, the Biometric Timekeeping System, data management, timekeeping, and 

payroll.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. ENTERPRISE 

LEASING further objects to the extent this request seeks documents that are not in its 

possession, but instead possessed by third-parties. ENTERPRISE LEASING objects to 

Plaintiffs’ use of the words and phrases “data management, timekeeping, and payroll” to the 

extent they call for a legal conclusion and on the grounds that they are undefined, vague, and 

ambiguous. Further, ENTERPRISE LEASING further objects to this Request on the basis that it 

seeks information on matters that are not stated with the requisite reasonable particularity, is 

unlimited in temporal or geographic scope, and seeks information outside the relevant statute of 

limitations. ENTERPRISE LEASING objects to this Request on the grounds that it is overbroad, 

vague, and ambiguous, and seeks information that is neither relevant to any party’s claim or 

defense nor proportional to the needs of the case. ENTERPRISE LEASING objects to this 

Request to the extent it seeks confidential information concerning individuals who are not a party 

to this lawsuit. ENTERPRISE LEASING also objects that this Request seeks confidential and/or 

proprietary information. 

Subject to and without waiving its general and specific objections, ENTERPRISE 

LEASING refers Plaintiff to all documents that will be produced in response to Plaintiff’s First 

Request for Production of Documents upon entry of a protective order. Additionally, on the basis 

of the foregoing objections, ENTERPRISE LEASING is withholding documents responsive to 

this Request.

REQUEST NO. 5: All Documents, Including all Data, Relating to any software, 

vendors, contractors, equipment, hardware, or any other item or object, whether tangible or 

intangible, Related To employee timekeeping, data privacy or protection, cybersecurity, and 

employee management, including the subject Biometric Timekeeping System.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. ENTERPRISE 

LEASING further objects to the extent this request seeks documents that are not in its 

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possession, but instead possessed by third-parties. ENTERPRISE LEASING objects to 

Plaintiffs’ use of the words and phrases “timekeeping, data privacy or protection, cybersecurity, 

and employee management” to the extent they call for a legal conclusion and on the grounds that 

they are undefined, vague, and ambiguous. Further, ENTERPRISE LEASING further objects to 

this Request on the basis that it seeks information on matters that are not stated with the requisite 

reasonable particularity, is unlimited in temporal or geographic scope, and seeks information 

outside the relevant statute of limitations. ENTERPRISE LEASING objects to this Request on 

the grounds that it is overbroad, vague, and ambiguous, and seeks information that is neither 

relevant to any party’s claim or defense nor proportional to the needs of the case. ENTERPRISE 

LEASING objects to this Request to the extent it seeks confidential information concerning 

individuals who are not a party to this lawsuit. ENTERPRISE LEASING also objects that this 

Request seeks confidential and/or proprietary information. 

Subject to and without waiving its general and specific objections, ENTERPRISE 

LEASING refers Plaintiff to all documents that will be produced in response to Plaintiff’s First 

Request for Production of Documents upon entry of a protective order. Additionally, on the basis 

of the foregoing objections, ENTERPRISE LEASING is withholding documents responsive to 

this Request.

REQUEST NO. 6: All Documents, Including all Data, Relating to any insurance 

agreement or policy which may satisfy in whole or in part any judgment which may be entered in 

this Lawsuit or to indemnify or reimburse for payments made to satisfy any such judgment or 

costs of defense or other litigation costs or expenses arising from this Lawsuit.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. ENTERPRISE 

LEASING further objects to the extent this request seeks documents that are not in its 

possession, but instead possessed by third-parties. ENTERPRISE LEASING objects to 

Plaintiffs’ use of the words and phrases “insurance agreement or policy” to the extent they call 

for a legal conclusion and on the grounds that they are undefined, vague, and ambiguous. 

Further, ENTERPRISE LEASING further objects to this Request on the basis that it seeks 

information on matters that are not stated with the requisite reasonable particularity, is unlimited 

in temporal or geographic scope, and seeks information outside the relevant statute of 

limitations. ENTERPRISE LEASING objects to this Request on the grounds that it is overbroad, 

vague, and ambiguous, and seeks information that is neither relevant to any party’s claim or 

defense nor proportional to the needs of the case. ENTERPRISE LEASING objects to this 

Request to the extent it seeks confidential information concerning individuals who are not a party 

to this lawsuit. ENTERPRISE LEASING also objects that this Request seeks confidential and/or 

proprietary information.

Subject to and without waiving its general and specific objections, ENTERPRISE 

LEASING refers Plaintiff to all documents that will be produced in response to Plaintiff’s First 

Request for Production of Documents upon entry of a protective order. Additionally, on the basis 

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of the foregoing objections, ENTERPRISE LEASING is withholding documents responsive to 

this Request.

REQUEST NO. 7: All Documents, Including all Data, You intend to use to support 

any affirmative defense to Plaintiff’s Complaint.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. Further, 

ENTERPRISE LEASING further objects to this Request on the basis that it seeks information on 

matters that are not stated with the requisite reasonable particularity, is unlimited in temporal 

scope, and seeks information outside the relevant statute of limitations. ENTERPRISE 

LEASING objects to the extent this Request seeks work product, trial preparation materials, 

identification of documents prepared after the commencement of this litigation, communications 

protected from disclosure by the attorney-client privilege, or documents protected from 

disclosure by any applicable law, rule, privilege or immunity. 

On the basis of the foregoing objections, ENTERPRISE LEASING is withholding 

documents on the basis of the foregoing objections.

REQUEST NO. 8: All Documents, Including all Data, sufficient to demonstrate or 

evidence the total number of individuals in Illinois who used or were otherwise subject to any 

biometric system owned, leased, controlled, or possessed by You, or any Biometric Timekeeping 

System located within any facility in Illinois owned, leased, controlled, or possessed by You, 

during the Relevant Time Period.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. Further, 

ENTERPRISE LEASING further objects to this Request on the basis that it seeks information on 

matters that are not stated with the requisite reasonable particularity, is unlimited in temporal 

scope, and seeks information outside the relevant statute of limitations. ENTERPRISE 

LEASING objects to this Request on the grounds that it is overbroad, vague, and ambiguous, and 

seeks information that is neither relevant to any party’s claim or defense nor proportional to the 

needs of the case. ENTERPRISE LEASING objects to the Request to the extent that it seeks 

information relating to individuals beyond the named Plaintiffs, on the grounds that it is overly 

broad, unduly burdensome, and seek information that is neither relevant to the pending action 

nor reasonably calculated to lead to the discovery of admissible evidence, and because the case 

has not been certified as a class action. ENTERPRISE LEASING objects to this Request to the 

extent it seeks confidential information concerning individuals who are not a party to this 

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lawsuit. . ENTERPRISE LEASING also objects that this Request seeks confidential and/or 

proprietary information. 

On the basis of the foregoing objections, ENTERPRISE LEASING is withholding 

documents on the basis of the foregoing objections.

.

REQUEST NO. 9: All Documents, Including all Data, sufficient to demonstrate or 

evidence the total number of individuals in Illinois who used or were otherwise subject to any 

biometric system owned, leased, controlled, or possessed by You, or any Biometric Timekeeping 

System located within any facility in Illinois owned, leased, controlled, or possessed by You, 

during the Relevant Time Period.

RESPONSE:

ENTERPRISE LEASING objects to this Request on the grounds that it fails to describe 

the documents requested with reasonable particularity as required by applicable law. 

ENTERPRISE LEASING objects to this Request as overbroad and unduly burdensome to the 

extent this requests seeks information that is irrelevant to Plaintiffs’ claims. Further, 

ENTERPRISE LEASING further objects to this Request on the basis that it seeks information on 

matters that are not stated with the requisite reasonable particularity, is unlimited in temporal 

scope, and seeks information outside the relevant statute of limitations. ENTERPRISE 

LEASING objects to this Request on the grounds that it is overbroad, vague, and ambiguous, and 

seeks information that is neither relevant to any party’s claim or defense nor proportional to the 

needs of the case. ENTERPRISE LEASING objects to the Request to the extent that it seeks 

information relating to individuals beyond the named Plaintiffs, on the grounds that it is overly 

broad, unduly burdensome, and seek information that is neither relevant to the pending action 

nor reasonably calculated to lead to the discovery of admissible evidence, and because the case 

has not been certified as a class action. ENTERPRISE LEASING objects to this Request to the 

extent it seeks confidential information concerning individuals who are not a party to this 

lawsuit. . ENTERPRISE LEASING also objects that this Request seeks confidential and/or 

proprietary information. 

On the basis of the foregoing objections, ENTERPRISE LEASING is withholding 

documents on the basis of the foregoing objections.

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DATED: July 21, 2021 Respectfully submitted,

Thomas E. Ahlering, IL No. 6295744

tahlering@seyfarth.com

Alexandra S. Oxyer, IL 6324449

aoxyer@seyfarth.com

SEYFARTH SHAW LLP

233 S. Wacker Dr., Suite 8000

Chicago, Illinois 60606

Telephone: 312-460-5000

Facsimile: 312-460-7000

Counsel for Defendants

ENTERPRISE LEASING COMPANY OF 

CHICAGO, LLC

By: s/Thomas E. Ahlering

 Thomas E. Ahlering.

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CERTIFICATE OF SERVICE

I hereby certify that on this 21st day of July, 2021, I served the foregoing on the counsel 

of record by electronic mail and U.S. Mail:

/s/Thomas E. Ahlering

Thomas E. Ahlering

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