EXHIBIT E

Case: 1:20-cv-03200 Document #: 56-5 Filed: 12/03/21 Page 1 of 3 PageID #:431
From: Yovanic, Jr., Paul J PYovanic@seyfarth.com

Subject: RE: Wordlaw v. Enterprise - 20-cv-03200 - Plf's Draft JSR Due Today

Date: October 25, 2021 at 5:01 PM

To: Brendan Duffner bduffner@mcgpc.com, Timothy Kingsbury tkingsbury@mcgpc.com

Cc: Dixon, Brandon L. bdixon@seyfarth.com, Cockroft, Andrew R. ACockroft@seyfarth.com

Hi Brendan:

Thank you for your email. I can assure you that we have been working diligently on this

and we can provide the following update.

We have made significant progress on obtaining signed consent forms for putative class

members. Our client has been able to retrieve signed forms for current employees. 

Among the current employees, we compiled signed consent forms for all of them, except

for a few we are trying to run down.

With respect to former employees, tracking down their consent proved to be a

cumbersome process due to several technical issues related to the exit process. Across

all Enterprise locations, there are over 4,000 former employees since 2016. However, as

we have discussed previously, not every Enterprise location in Illinois utilized the

timekeeping system at issue. As a result, we needed to develop a strategy to cull that

data to something manageable, and then retrieve the personnel files from the smaller,

relevant pool of former employees. 

We managed to streamline the pool of former employees, and we are now at the stage of

looking through those personnel files and pulling the consent forms. Many of the

personnel files are housed in offsite storage facilities, which the client was unable to

obtain until last week. Our client anticipates completing the review of those files by the

end of the month, if not earlier.

We remain committed to getting you information by the end of the month, as promised. 

As you can see, we have been working diligently to compile the necessary information to

support our position and help you evaluate potential class issues. Please let us know if

you would like to set up a call next week to figure out what makes most sense in terms of

production of information for current employees, and to discuss any questions you may

have about the collection process. 

We thank you again for your patience while we sort through the information.

Best,

Paul

Paul J Yovanic Jr. | Associate | Seyfarth Shaw LLP

233 S. Wacker Drive | Suite 8000 | Chicago, Illinois 60606-6448

Direct: +1-312-460-5898 | Fax: +1-312-460-7095

pyovanic@seyfarth.com | www.seyfarth.com

Case: 1:20-cv-03200 Document #: 56-5 Filed: 12/03/21 Page 2 of 3 PageID #:432
CONFIDENTIALITY WARNING: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). Any

unauthorized use or disclosure of this communication is prohibited. If you believe that you have received this email in error, please notify the sender

immediately and delete it from your system.

From: Brendan Duffner <bduffner@mcgpc.com> 

Sent: Monday, October 25, 2021 3:47 PM

To: Timothy Kingsbury <tkingsbury@mcgpc.com>

Cc: Yovanic, Jr., Paul J <PYovanic@seyfarth.com>; Ahlering, Thomas E.

<TAhlering@seyfarth.com>; Dixon, Brandon L. <bdixon@seyfarth.com>

Subject: Re: Wordlaw v. Enterprise - 20-cv-03200 - Plf's Draft JSR Due Today

[EXT. Sender]

Paul,

Please advise regarding the status of Defendants’ production of documents, as we are

beyond the production date identified in the Parties’ September 30th Joint Status Report.

Thanks,

Brendan

Brendan Duffner | Attorney

MCGUIRE LAW, P.C.

55 West Wacker Drive, 9th Fl. [google.com]

Chicago, Illinois 60601

bduffner@mcgpc.com

T: (312) 893-7002 ext. *1

F: (312) 275-7895

Cell: (815) 370-2270

www.mcgpc.com [mcgpc.com]

Case: 1:20-cv-03200 Document #: 56-5 Filed: 12/03/21 Page 3 of 3 PageID #:433