EXHIBIT D

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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,

Plaintiff,

v.

ENTERPRISE LEASING COMPANY OF 

CHICAGO, LLC; ENTERPRISE 

HOLDINGS, INC.,

Defendant.

Case No. 1:20-CV-03200

Honorable Manish S. Shah

Honorable Magistrate Gabriel A. Fuentes

DEFENDANT ENTERPRISE LEASING COMPANY OF CHICAGO, LLC’S 

RESPONSES TO PLAINTIFF’S FIRST SET OF INTERROGATORIES

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Defendant 

ENTERPRISE LEASING COMPANY OF CHICAGO, LLC (“ENTERPRISE LEASING” or 

“Defendant”), by and through its attorneys, hereby submits its Responses and Objections 

(“Responses”) to Plaintiff’s First Interrogatories Propounded on Enterprise Leasing

(“Interrogatories”). 

 

PRELIMINARY STATEMENT/RESERVATION OF RIGHTS

ENTERPRISE LEASING submits its responses to the Interrogatories expressly reserving 

and without waiver of: (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 Interrogatories, any information 

contained therein, or any documents produced in response to the Interrogatories, 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 Interrogatories, other discovery requests, or proceedings involving or 

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related to the subject matter of the Interrogatories, information, or documents ENTERPRISE 

LEASING has provided or may provide in response to the Interrogatories; 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. Further, 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. 

These responses are subject to amendment and supplementation as ENTERPRISE 

LEASING acquires additional information and completes its review and analysis. 

ENTERPRISE LEASING’s responses to the Interrogatories were prepared in consultation with 

its attorneys and may not exactly match the words or phrases that might be used by individual 

employees in the course of this litigation to describe events, policies, or matters discussed herein.

OBJECTIONS TO ALL INTERROGATORIES

1. ENTERPRISE LEASING objects to the Interrogatories, and to the definitions and 

instructions accompanying the Interrogatories, to the extent they seek or purport to impose 

definitions, instructions, or obligations outside of those imposed by Rules 26 and 33 of the 

Federal Rules of Civil Procedure, the Local Civil Rules of this Court, or the Orders of this Court. 

ENTERPRISE LEASING will respond to the Interrogatories in accordance with its obligations 

as set forth in those Rules and/or Orders. 

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, 

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.

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3. ENTERPRISE LEASING objects to the Interrogatories 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.

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.

RESPONSES TO PLAINTIFFS’ INTERROGATORIES 

INTERROGATORY NO. 1:

Identify each Person known to You to have knowledge or information relevant to the 

facts and the claims asserted in Plaintiff’s Complaint and indicate the scope and nature of such 

Person’s knowledge.

RESPONSE TO NO. 1:

Defendant further objects to Plaintiff’s use of the phrase “relevant to the facts and the 

claims asserted” to the extent it calls for a legal conclusion. Defendant objects to this 

Interrogatory 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. Defendant objects to this Interrogatory on the grounds that it 

is unduly burdensome, 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. 

Without waiving the foregoing objections, see Defendant’s Rule 26(a) Initial Disclosures. 

INTERROGATORY NO. 2:

Identify each Person (other than Your attorneys) who assisted in the preparation of Your 

responses to these interrogatories and the specific interrogatories with which each such Person 

assisted and list all documents You consulted to prepare Your answers to these interrogatories.

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RESPONSE TO NO. 2:

Defendant objects to this Interrogatory on the basis of attorney-client privilege, work 

product doctrine, or any other applicable privilege or protection. Without waiving the foregoing 

objections, Defendant states:

1. Jennifer Mecklenburg, Enterprise Leasing Company of Chicago, LLC

INTERROGATORY NO. 3:

Identify each and every Person and/or department and/or other corporate unit responsible 

for, involved in, or that assisted in the development of any of Your policies or practices 

concerning personal data, data privacy or protection, or cybersecurity, including any policies 

related to Biometrics.

RESPONSE TO NO. 3:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“responsible for,” “involved in,” and “assisted in” as they are vague and ambiguous. Defendant 

objects to this Interrogatory 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. Defendant objects to this Interrogatory on the grounds 

that it is unduly burdensome, 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. 

Defendant objects to this Interrogatory on the basis of attorney-client privilege, work product 

doctrine, or any other applicable privilege or protection.

Without waiving the foregoing objections, see Defendant’s Responses to Plaintiffs’ First 

Requests for Production of Documents. 

INTERROGATORY NO. 4:

Describe and explain, in detail, all of Your policies, practices, or procedures concerning 

personal data, data privacy or protection, or cybersecurity, including any policies related to 

Biometrics. Include the date of implementation of any such policies, practices, or procedures.

RESPONSE TO NO. 4:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“describe and explain, in detail,” to the extent they are vague, ambiguous and undefined. 

Defendant objects to this Interrogatory 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 

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information outside the relevant statute of limitations. Defendant objects to this Interrogatory on 

the grounds that it is unduly burdensome, 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. Defendant objects to the Interrogatory to the extent that it seeks information 

inappropriate for an interrogatory. 

Without waiving the foregoing objections, see Defendant’s Responses to Plaintiffs’ First 

Requests for Production of Documents. 

INTERROGATORY NO. 5:

Describe any and all measures, steps, and otherwise actions taken by You to inform the 

public regarding, or make available to the public, any policies, practices, and procedures 

concerning personal data, data privacy or protection, or cybersecurity, including any policies 

related to Biometrics and the retention or destruction of Biometrics.

RESPONSE TO NO. 5:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“any and all measures, steps, and otherwise actions,” “to inform the public regarding, or make 

available to the public,” “any policies, practices, and procedures,” “personal data,” “data privacy 

or protection,” and “cybersecurity” to the extent they call for a legal conclusion or are vague, 

ambiguous, and undefined. Defendant objects to this Interrogatory 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. Defendant 

objects to this Interrogatory on the grounds that it is unduly burdensome, 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. 

Without waiving the foregoing objections, see Defendant’s Responses to Plaintiffs’ First 

Requests for Production of Documents. 

INTERROGATORY NO. 6:

If they exist, describe and explain, in detail, when all of Your policies, practices, or 

procedures Related to Biometrics were created, updated, implemented, discontinued, and/or 

evaluated, and the Person or entity which created, updated, implemented discontinued, and/or 

evaluated each such policy, practice, or procedure.

RESPONSE TO NO. 6:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

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“policies, practices, and procedures,” to the extent they call for a legal conclusion or are vague, 

ambiguous, and undefined. Defendant objects to this Interrogatory 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. Defendant 

objects to this Interrogatory on the grounds that it is unduly burdensome, 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. 

Without waiving the foregoing objections, Defendant states that it has a policy related to 

biometrics, which was created in 2016. Further, see Defendant’s Responses to Plaintiffs’ First 

Requests for Production of Documents. 

INTERROGATORY NO. 7:

For the Relevant Time Period, Identify the Persons most knowledgeable with regard to 

the technological and data processes associated with the flow of data involved in the Biometric 

Timekeeping System.

RESPONSE TO NO. 7:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“most knowledgeable,” “technological and data processes,” and “associated with the flow of 

data” to the extent they call for a legal conclusion and are vague, ambiguous, and undefined.” 

Defendant further objects to Plaintiff’s use of the terms “captured, collected, processed, stored, 

or used,” as undefined, vague, and ambiguous and to the extent they call for a legal conclusion. 

Defendant objects to this Interrogatory 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. Defendant objects to this Interrogatory on 

the grounds that it is unduly burdensome, 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. 

 

INTERROGATORY NO. 8:

Describe in detail the process(es) by which You provide Data and Documents to Any 

Third Party, vendor, or other Person or entity in order to facilitate the conducting of payroll 

processing and employee time management, including the identity and role of any software, 

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

intangible, involved in such process(es).

RESPONSE TO NO. 8:

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Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“provide,” and “involved in such process(es)” as undefined, vague, and ambiguous. Defendant 

objects to this Interrogatory 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. Defendant objects to this Interrogatory on the grounds 

that it is unduly burdensome, 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. 

Without waiving the foregoing objections, Defendant states that it has not transmitted any 

individual’s biometric information or data to any third-party entity. 

INTERROGATORY NO. 9:

If you contend that You do not violate any state or federal laws related to biometric 

collection or biometric timekeeping, state the basis, including application of law to fact, for this 

contention.

RESPONSE TO NO. 9:

Defendant objects to Plaintiff’s use of the terms “state or federal laws related to biometric 

collection or biometric timekeeping,” as undefined, vague, and ambiguous and to the extent they 

call for a legal conclusion. Defendant objects to this Interrogatory 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. Defendant 

objects to this Interrogatory on the grounds that it is unduly burdensome, 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. Defendant finally objects to this Interrogatory to the extent 

it calls for information protected by the attorney-client privilege or attorney work product 

doctrines.

Without waiving the foregoing objections, Defendant states that it does not violate any 

state or federal laws related to biometric collection or biometric timekeeping. 

 

INTERROGATORY NO. 10:

Identify all Data and/or Documents generated and/or provided by You or made available 

by You to Any Third Party, any vendor, or any other Person or entity to facilitate the 

provisioning of any and all services Related To the Biometric Timekeeping System, including 

timekeeping or payroll processing services. For any such Third Party, vendor, or other Person, 

Describe (i) the process by which You generated and/or provided such Data and/or Documents to 

such third party, vendor, or person, including the frequency if such Data or Documents are 

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recurring in nature, (ii) the Data or Document from which the subject Data or Document is 

generated, derived, or prompted, (iii) the manner in which You store, use, and/or process the 

Data and/or Document for payroll processing purposes, and (iv) any and all known technical 

formats of the Data and/or Document.

RESPONSE TO NO. 10:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“provide,” “made available,” “process,” “generated, derived, or prompted,” “store, use, and/or 

process,” and “technical formats” as undefined, vague, and ambiguous. Defendant objects to this 

Interrogatory 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. Defendant objects to this Interrogatory on the grounds that it 

is unduly burdensome, 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. 

Without waiving the foregoing objections, Defendant states that it has not transmitted any 

individual’s biometric information or data to any third-party entity. 

INTERROGATORY NO. 11:

Identify all Persons and/or entities who were ever in possession of any of the Data and/or 

Documents identified/described in response to Interrogatory No. 10, Including but not limited to 

all Persons or entities to whom, or from whom, any Data and/or Documents identified/described 

in response to Interrogatory No. 10, is transmitted, disseminated, disclosed, or redisclosed.

RESPONSE TO NO. 11:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“transmitted, disseminated, disclosed, or redisclosed” as undefined, vague, and ambiguous. 

Defendant objects to this Interrogatory 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. Defendant objects to this Interrogatory on 

the grounds that it is unduly burdensome, 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. 

Without waiving the foregoing objections, Defendant states that it has not transmitted any 

individual’s biometric information or data to any third-party entity. 

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INTERROGATORY NO. 12:

To the extent that any Data or Documents identified or described in response to 

Interrogatory No. 10 was transmitted, disseminated, disclosed, or redisclosed to any Person or 

entity by You, Identify and Describe the process(es) by which such Data or Documents was 

transmitted, disseminated, disclosed, or redisclosed, Including but not limited to the technology 

utilized for such transmission, dissemination, disclosure or redisclosure.

RESPONSE TO NO. 12:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“transmitted, disseminated, disclosed, or redisclosed” as undefined, vague, and ambiguous. 

Defendant objects to this Interrogatory 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. Defendant objects to this Interrogatory on 

the grounds that it is unduly burdensome, 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. 

Without waiving the foregoing objections, Defendant states that it has not transmitted any 

individual’s biometric information or data to any third-party entity. 

INTERROGATORY NO. 13:

If you contend that any Data or Documents that You receive, use, or rely upon to track 

the time of Your employees and/or workers on Your behalf does not constitute Biometrics, 

explain the legal and factual basis for such contention, and Identify all Data and Documents You 

contend support such basis.

RESPONSE TO NO. 13:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“Biometrics” to the extent it calls for a legal conclusion and “receive, use, or rely upon” as 

vague, ambiguous, and undefined. Defendant objects to this Interrogatory 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. 

Defendant objects to this Interrogatory on the grounds that it is unduly burdensome, 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. Defendant finally objects to this Interrogatory 

to the extent it calls for information protected by the attorney-client privilege or attorney work 

product doctrines.

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Without waiving the foregoing objections, Defendant states that it does not collect, 

capture, or possess biometric information. 

INTERROGATORY NO. 14:

Identify and describe in detail any agreement, whether in writing or otherwise, between 

You and any staffing agency for the provisioning of any service whatsoever. For each such 

agreement, Identify all Data and Documents concerning or memorializing the same.

RESPONSE TO NO. 14:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“staffing agency” and “provisioning of any service” to the extent it calls for a legal conclusion 

and is vague, ambiguous, and undefined. Defendant objects to this Interrogatory 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. 

Defendant objects to this Interrogatory on the grounds that it is unduly burdensome, 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. Defendant objects to the Interrogatories as 

overly broad, unduly burdensome, and not proportionate to the needs of this case.

INTERROGATORY NO. 15:

Identify and describe in detail any agreement, whether in writing or otherwise, between 

You and any other Person or entity for the provisioning of staffing services for You in Illinois at 

any time during the Relevant Time Period.

RESPONSE TO NO. 15:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“provisioning of staffing services” to the extent it calls for a legal conclusion and is vague, 

ambiguous, and undefined. Defendant objects to this Interrogatory 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. Defendant 

objects to this Interrogatory on the grounds that it is unduly burdensome, 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. Defendant objects to the Interrogatories as overly broad, 

unduly burdensome, and not proportionate to the needs of this case.

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INTERROGATORY NO. 16:

Identify the total number of individuals in Illinois who were employed by You, worked 

for You pursuant to a third-party staffing arrangement, or worked in any of Your facilities in 

Illinois during the Relevant Time Period.

RESPONSE TO NO. 16:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the term 

“third-party staffing arrangement” to the extent they call for a legal conclusion, and “worked in 

any of your facilities” as undefined, vague and ambiguous. Defendant objects to this 

Interrogatory 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. Defendant objects to this Interrogatory on the grounds that it 

is unduly burdensome, 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. Defendant 

objects to the Interrogatory to the extent that it seeks information relating to individuals beyond 

the named Plaintiff, on the grounds that it is overly broad, unduly burdensome, and seeks 

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. 

INTERROGATORY NO. 17:

Identify and Describe the process, if any, by which You obtain consent and/or otherwise 

inform individuals that You are collecting, capturing, storing, handling, obtaining, or otherwise 

using their Biometrics and/or other information or Data pertaining to such individuals. Include 

the implementation date of such process(es).

RESPONSE TO NO. 17:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant objects to this Interrogatory 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. 

Defendant objects to this Interrogatory on the grounds that it is unduly burdensome, 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. 

Without waiving the foregoing objections, Defendant states that employees are asked to 

provide electronic and written consent for the collection, capture, storage, handling, obtaining, or 

use of biometric information prior to using any timekeeping system at issue in this matter. Such 

consent procedures were implemented in 2016, when Defendant began utilizing the timekeeping 

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systems at issue in this matter. Further, see Defendant’s Responses to Plaintiffs’ First Requests 

for Production of Documents.

INTERROGATORY NO. 18:

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

any Biometric Timekeeping 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 TO NO. 18:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the term 

“law relating to biometric information” to the extent they call for a legal conclusion, and “how 

you first learned in any manner” as undefined, vague and ambiguous. Defendant objects to this 

Interrogatory 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. Defendant objects to this Interrogatory on the grounds that it 

is unduly burdensome, 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. Defendant 

objects to the Interrogatory to the extent that it seeks information relating to individuals beyond 

the named Plaintiff, on the grounds that it is overly broad, unduly burdensome, and seeks 

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. 

Defendant objects to this Interrogatory to the extent it seeks confidential information concerning 

individuals who are not a party to this lawsuit. Defendant finally objects to this Interrogatory to 

the extent it calls for information protected by the attorney-client privilege or attorney work 

product doctrines. 

INTERROGATORY NO. 19:

Identify and Describe 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, including the policy number and applicable limits for each 

such insurance agreement or policy. You may produce a copy of said insurance policy in lieu of 

any Identification and Description.

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RESPONSE TO NO. 19:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the term 

“law relating to biometric information” to the extent they call for a legal conclusion, and “how 

you first learned in any manner” as undefined, vague and ambiguous. Defendant objects to this 

Interrogatory 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. Defendant objects to this Interrogatory on the grounds that it 

is unduly burdensome, 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. Defendant 

objects to the Interrogatory to the extent that it seeks information relating to individuals beyond 

the named Plaintiff, on the grounds that it is overly broad, unduly burdensome, and seeks 

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. 

Defendant objects to this Interrogatory to the extent it seeks confidential information concerning 

individuals who are not a party to this lawsuit. Defendant finally objects to this Interrogatory to 

the extent it calls for information protected by the attorney-client privilege or attorney work 

product doctrines. 

INTERROGATORY NO. 20:

With respect to the Biometric Timekeeping System at issue in this Lawsuit, identify and 

describe all device(s) that store an encrypted mathematical representation of an employee’s 

fingerprint, including Identifying the device(s)’ purchaser, owner, installer, and manufacturer.

RESPONSE TO NO. 20:

Defendant objects to this Interrogatory as it contains subparts and presents compound, 

conjunctive, or disjunctive questions. Defendant further objects to Plaintiff’s use of the terms 

“encrypted mathematical representation,” and “device(s)’ purchaser, owner, installer, and 

manufacturer,” to the extent they call for a legal conclusion and are vague, ambiguous and 

undefined. Defendant objects to this Interrogatory 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. Defendant objects to this 

Interrogatory on the grounds that it is unduly burdensome, 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. Defendant objects to the Interrogatory to the extent that it seeks 

information inappropriate for an interrogatory. 

Without waiving the foregoing objections, see Defendant’s Responses to Plaintiffs’ First 

Requests for Production of Documents

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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 

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

/s/Thomas E. Ahlering

Thomas E. Ahlering

Case: 1:20-cv-03200 Document #: 56-4 Filed: 12/03/21 Page 16 of 16 PageID #:430