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

SEVENTH JOINT REPORT ON THE STATUS OF DISCOVERY

Pursuant to the Court’s June 8, 2022 Order, ECF 126, Plaintiffs Mark Hansen and Jason 

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

seventh joint report on the status of discovery.

I. Production of ESI and Other Documents

Since the last joint status report, United made its tenth production of documents responsive 

to Plaintiffs’ First Requests for the Production of Documents (the “Requests”) on June 14, 2022. 

United is continuing to collect and review additional documents responsive to Plaintiffs’ Requests 

and expects to make an additional production on or before July 13, 2022 . Among other things, 

United expects that production may consist of additional raw data, emails, attachments, and other 

ESI. With respect to the omnibus dataset referenced in the parties’ Joint Motion to Modify Case 

Management Schedule, ECF 127, that dataset has been re-run and United is currently working to 

validate it prior to production. United expects to be able to produce the revised dataset on or before 

July 15, 2022. 

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Plaintiff Buffer, for his part, also made a second and third supplemental production of 

documents on July 1, 2022 and July 5, 2022, respectively.

Further, as the Court is aware, on February 10, 2022, Plaintiffs filed a motion to compel as 

to certain categories of documents sought in the Requests (ECF 111). United filed its response on

March 3, 2022 (ECF 116), and Plaintiffs filed their reply on March 21, 2022 (ECF 118).

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. Since then, the parties have resolved the majority of 

those objections and are working on scheduling specific dates. The parties expect to resolve the 

remaining objections, which concern a single deposition topic, in advance of the July 12, 2022 

status hearing. 

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

This case is set for a status hearing on July 12, 2022. The parties propose that the next 

status hearing be set for August 11, 2022, with the parties’ eighth joint report on the status of 

discovery to be submitted to the Court on August 9, 2022. 

Dated: July 10, 2022 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

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 

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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

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

Sondra A. Hemeryck

Valerie H. Brummel

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

vbrummel@rsch-law.com

bgerdes@rshc-law.com

Counsel for United Airlines, Inc.

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