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

SIXTEENTH JOINT REPORT ON THE STATUS OF DISCOVERY

Pursuant to the Court’s March 23, 2023, Order (ECF 160), Plaintiffs Mark Hansen and 

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

this sixteenth 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. 

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 

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

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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 September 27, 2022 Order (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 will 

exchange their Rule 26(a)(2) disclosures on April 20, 2023. The parties also expect to exchange 

rebuttal expert reports by May 22, 2023, per the January 27, 2023 Order. At this time, the parties 

anticipate that there will need to be depositions of each party’s expert witness(es), which the parties 

agree should occur after the exchange of rebuttal reports. Given that, and the Court’s direction in 

its most recent order (ECF 160) to address scheduling for expert depositions in this status report, 

the parties propose that the current deadline for the close of expert discovery be extended by three

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weeks, from May 22, 2023, to June 12, 2023, to allow for expert depositions after the exchange of 

rebuttal reports. To accommodate that three-week extension, the parties also propose that the 

existing deadlines for class certification briefing be extended by three weeks, as set forth below:

Event Existing Deadline Revised Deadline

Parties to exchange Rule 26(a)(2) expert 

disclosures

April 20, 2023 April 20, 2023 (no 

change)

Parties to exchange expert rebuttal reports May 22, 2023 May 22, 2023 (no 

change)

Expert discovery to be completed May 22, 2023 June 12, 2023

Plaintiffs to file their motion for class certification June 5, 2023 June 26, 2023

United to file its response to motion for class 

certification

July 11, 2023 August 1, 2023

Plaintiffs to file their reply in support of motion 

for class certification

August 8, 2023 August 29, 2023

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

The parties propose that the parties’ seventeenth joint report on the status of discovery be 

submitted to the Court on May 10, 2023.

Dated: April 10, 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

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 

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455 N. Cityfront Plaza Dr., Suite 2410

Chicago, IL 60611

(708) 628-4949

dank@hbsslaw.com

whitneys@hbsslaw.com

Interim Co-Lead Counsel

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

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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