KENDALL J. NEWMAN, Magistrate Judge.
On November 7, 2014, the court held an informal telephonic conference pursuant to the parties' request to address the parties' discovery disputes concerning certain interrogatories and requests for production propounded by plaintiff United Genetics Turkey Tohum Fide, A.S. ("plaintiff"). Attorney Effie Anastassiou appeared telephonically on behalf of plaintiff. Attorney Sean Flynn appeared on behalf of defendants H.J. Heinz Company and Heinzseed (collectively "defendants"). Prior to this telephonic conference, the parties provided the court with a joint statement setting forth each party's respective position regarding the discovery issues addressed during the conference.
After considering the parties' joint statement, the relevant portions of the record, the parties' oral arguments, the applicable law, the agreement of the parties, and for the reasons stated during the telephonic conference, IT IS HEREBY ORDERED that:
1. Defendants shall provide plaintiff with responses to special interrogatory numbers 18, 19, 20, and 23 as soon as it is practicable to do so.
2. In their current form, special interrogatory numbers 33 and 34 are compound in nature and, therefore, exceed the 45 interrogatory limit to which the parties have stipulated. Counsel for the parties shall meet and confer regarding how they wish to proceed with addressing the questions posed by these interrogatories.
3. Counsel for the parties shall also meet and confer regarding their issues concerning plaintiff's requests for production of documents. Specifically, counsel should discuss defendants' projected timeline for producing documents responsive to these requests, any objections defendants may have as to these requests, and any privileges defendants believe they may assert with respect to any documents responsive to these requests. Furthermore, counsel should address and work towards an agreement on the search parameters defendants will use in reviewing any electronically stored information in connection with developing their responses to these requests.
4. Defendants' counsel shall provide plaintiff's counsel with the letter responding to plaintiff's document requests that was referred to by defendants' counsel during the telephonic conference by no later than 12:00 P.M. on November 10, 2014.
5. A further informal telephonic conference is scheduled for November 18, 2014, at 9:00 A.M., before the undersigned to discuss the parties' progress in addressing their remaining discovery issues. Prior to this telephonic conference, counsel for plaintiff shall contact the undersigned's courtroom deputy at (916) 930-4187 to inform the court of the phone number(s) at which counsel for the parties can be reached at the above-scheduled time. The court expects counsel for the parties to have met and conferred with one another as directed above prior to this further telephonic conference. The parties do not need to provide the court with a joint statement or other filing prior to the telephonic conference, but may do so if the parties believe that such a filing will provide further assistance to the court regarding the issues to be addressed at the telephonic conference.