EXHIBIT A

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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.,

Defendant.

Case No. 20-cv-03200

Honorable Manish S. Shah

Honorable Magistrate Gabriel A. Fuentes

DEFENDANT ENTERPRISE HOLDINGS, INC.’S RESPONSES TO PLAINTIFF’S

FIRST REQUESTS FOR PRODUCTION

Defendant ENTEPRISE HOLDINGS, INC. (“ENTERPRISE HOLDINGS” 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 HOLDINGS 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 HOLDINGS’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 

HOLDINGS has provided or may provide in response to the Requests; and (c) the right at any 

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time to review, revise, correct, add to, supplement, amend, or clarify any of the responses 

propounded herein.

ENTERPRISE HOLDINGS 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 HOLDINGS bases its responses and objections on information 

now known to ENTERPRISE HOLDINGS. ENTERPRISE HOLDINGS 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 HOLDINGS objects to the Requests to the extent that they imply 

or assume that ENTERPRISE HOLDINGS was collecting, capturing, processing, using, 

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

information or data. ENTERPRISE HOLDINGS 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

 

2. ENTERPRISE HOLDINGS 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. 

3. ENTERPRISE HOLDINGS 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 HOLDINGS has limited its responses to information and documents relative to 

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

4. 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 HOLDINGS does not 

waive any general objections not referred to in any particular answer. 

5. ENTERPRISE HOLDINGS 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 HOLDINGS 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 

HOLDINGS 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 HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request on the grounds that it fails to describe 

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

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

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

HOLDINGS 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 

HOLDINGS 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 

HOLDINGS 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 HOLDINGS objects that all individuals whose employment 

is relevant to this matter was not employed by ENTERPRISE HOLDINGS but rather one of its 

subsidiaries. ENTERPRISE HOLDINGS also objects that this Request seeks confidential and/or 

proprietary information. 

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

HOLDINGS 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 HOLDINGS objects to this Request on the grounds that it fails to describe 

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

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

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

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

possession, but instead possessed by third-parties. ENTERPRISE HOLDINGS 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 HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request to the 

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

lawsuit. ENTERPRISE HOLDINGS objects that all individuals whose employment is relevant 

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to this matter was not employed by ENTERPRISE HOLDINGS but rather one of its subsidiaries 

ENTERPRISE HOLDINGS also objects that this Request seeks confidential and/or proprietary 

information. 

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

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

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

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

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

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

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

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

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

a party to this lawsuit. ENTERPRISE HOLDINGS objects that all individuals whose 

employment is relevant to this matter was not employed by ENTERPRISE HOLDINGS but 

rather one of its subsidiaries ENTERPRISE HOLDINGS also objects that this Request seeks 

confidential and/or proprietary information. 

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

HOLDINGS 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 HOLDINGS 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:

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

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

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

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

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

possession, but instead possessed by third-parties. ENTERPRISE HOLDINGS 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 HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request to the extent it seeks confidential information 

concerning individuals who are not a party to this lawsuit. ENTERPRISE HOLDINGS objects 

that all individuals whose employment is relevant to this matter was not employed by 

ENTERPRISE HOLDINGS but rather one of its subsidiaries ENTERPRISE HOLDINGS also 

objects that this Request seeks confidential and/or proprietary information. 

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

HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request on the grounds that it fails to describe 

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

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

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

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

possession, but instead possessed by third-parties. ENTERPRISE HOLDINGS 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 HOLDINGS 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 HOLDINGS 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 

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claim or defense nor proportional to the needs of the case. ENTERPRISE HOLDINGS objects 

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

a party to this lawsuit. ENTERPRISE HOLDINGS also objects that this Request seeks 

confidential and/or proprietary information. 

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

HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request on the grounds that it fails to describe 

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

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

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

ENTERPRISE HOLDINGS 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 

HOLDINGS 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 HOLDINGS is withholding 

documents responsive to this Request. 

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 HOLDINGS objects to this Request on the grounds that it fails to describe 

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

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

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

ENTERPRISE HOLDINGS 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 

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HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request 

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

lawsuit. ENTERPRISE HOLDINGS objects that all individuals whose employment is relevant 

to this matter was not employed by ENTERPRISE HOLDINGS but rather one of its subsidiaries 

ENTERPRISE HOLDINGS also objects that this Request seeks confidential and/or proprietary 

information. 

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

documents on the basis of the foregoing objections.

REQUEST NO. 9: All Documents constituting, referring, or Relating To any contracts 

or written agreements that were entered into or in effect between You and Enterprise Chicago 

during the relevant time period.

RESPONSE:

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

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

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

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

HOLDINGS objects to Plaintiffs’ use of the words and phrases “contracts or written agreements”

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

and ambiguous. Further, ENTERPRISE HOLDINGS 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 and geographic scope, and seeks information outside the relevant statute 

of limitations. ENTERPRISE HOLDINGS 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 HOLDINGS objects 

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

a party to this lawsuit. ENTERPRISE HOLDINGS also objects that this Request seeks 

confidential and/or proprietary information.

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

HOLDINGS 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 HOLDINGS is withholding documents responsive to 

this Request.

REQUEST NO. 10: Produce all Documents referring or Relating To hardware, Data, or 

information shared between You and Enterprise Chicago Related to employee timekeeping.

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RESPONSE:

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

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

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

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

HOLDINGS objects to Plaintiffs’ use of the words and phrases “hardware, Data, or 

information,” and “shared” to the extent they call for a legal conclusion and on the grounds that 

they are undefined, vague, and ambiguous. Further, ENTERPRISE HOLDINGS 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 and geographic scope, and seeks 

information outside the relevant statute of limitations. ENTERPRISE HOLDINGS 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 HOLDINGS objects to this Request to the extent it seeks confidential information 

concerning individuals who are not a party to this lawsuit. ENTERPRISE HOLDINGS objects 

that all individuals whose employment is relevant to this matter was not employed by 

ENTERPRISE HOLDINGS but rather one of its subsidiaries. ENTERPRISE HOLDINGS also 

objects that this Request seeks confidential and/or proprietary information.

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

HOLDINGS 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 HOLDINGS is withholding documents responsive to 

this Request.

REQUEST NO. 11: All Documents, Including all Data, describing and identifying the 

requirements set forth by You for Your subsidiaries Related to employee timekeeping.

RESPONSE:

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

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

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

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

HOLDINGS objects to Plaintiffs’ use of the words and phrases “requirements” and “employee 

timekeeping” to the extent they call for a legal conclusion and on the grounds that they are 

undefined, vague, and ambiguous. Further, ENTERPRISE HOLDINGS 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 and geographic scope, and seeks information 

outside the relevant statute of limitations. ENTERPRISE HOLDINGS 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 

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

individuals who are not a party to this lawsuit. ENTERPRISE HOLDINGS objects that all 

individuals whose employment is relevant to this matter was not employed by ENTERPRISE 

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HOLDINGS but rather one of its subsidiaries. ENTERPRISE HOLDINGS also objects that this 

Request seeks confidential and/or proprietary information.

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

HOLDINGS 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 HOLDINGS is withholding documents responsive to 

this Request.

.

REQUEST NO. 12: Produce all Documents constituting, referring, or Relating To any 

contracts or written agreements that were entered into or in effect between You and any 

employee of Enterprise Chicago during the Relevant Time Period.

RESPONSE:

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

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

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

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

ENTERPRISE HOLDINGS 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 

HOLDINGS 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 HOLDINGS 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 HOLDINGS objects to this Request 

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

lawsuit. ENTERPRISE HOLDINGS objects that all individuals whose employment is relevant to 

this matter was not employed by ENTERPRISE HOLDINGS but rather one of its subsidiaries.

ENTERPRISE HOLDINGS also objects that this Request seeks confidential and/or proprietary 

information. 

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

documents responsive to this Request.

REQUEST NO. 13: All Documents, including all Data, sufficient to demonstrate or 

evidence the total number of Your Illinois subsidiaries that utilized biometric timekeeping 

system(s), or finger-scan systems during the Relevant Time Period.

RESPONSE:

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

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

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

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

HOLDINGS objects to Plaintiffs’ use of the words and phrases “Illinois subsidiaries” to the 

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

ambiguous. Further, ENTERPRISE HOLDINGS 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 HOLDINGS 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 HOLDINGS 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 HOLDINGS objects 

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

a party to this lawsuit. ENTERPRISE HOLDINGS also objects that this Request seeks 

confidential and/or proprietary information.

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

documents responsive to this Request.

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 HOLDINGS, INC.

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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