[PROPOSED] ORDER REGARDING DISCOVERY DISPUTE

WILLIAM H. ALSUP, District Judge.

ORDER

Pursuant to the Order Setting Hearing Re Plaintiffs' Discovery Dispute (Dkt. 68), the Parties conducted a meet-and-confer in the Court's jury room on October 17, 2017 from 9:00 a.m. to 11:00 a.m., following which the Court conducted a hearing. As a result of the meet-and-confer and hearing, IT IS HEREBY ORDERED:

1. Defendants Rent-A-Center, Inc. and Rent-A-Center West, Inc. ("RAC") shall, within thirty (30) days from the date of this Order, produce transactional data for rent-to-own transactions within California during the purported class period, which is contained within RAC's data warehouse and/or SIMS system and/or its Oracle Database/Inventory system(s) in an electronic format (i.e. the data shall be produced in a manipulable format) sufficient to calculate the formulas under the Karnette Act (e.g., maximum cash price and maximum total payments, etc.) and including the information in SIMS that would normally be reflected in Rental Purchase Agreements (e.g., categories (i)-(xi) in RFP No. 2) in response to Plaintiff Paula Blair's First Set of Requests for Production of Documents ("RFP") Nos. 1, 2, 7, 8, 16, 17, 24-34, 36, and 49. Without limiting the foregoing, the production shall include documents sufficient to establish the Lessor's Cost of each item of merchandise, as that term is defined in the RFP.

2. As for the physical rental purchase agreements and arbitration agreements regarding rent-to-own transactions within California during the purported class period, RAC will provide agreements reflecting 20 transactions. To the extent Plaintiff requests additional rental purchase agreements or arbitration agreements, Plaintiff's counsel shall cover all reasonable costs associated with locating, reviewing, and producing such documents. Further, given the manual review associated with fulfilling any such request, RAC shall have at least thirty (30) days to produce such documents. Either party may seek judicial guidance as to the scope and cost shifting of any such request as well as the deadline for complying with any such request.

3. Within thirty (30) days from the date of this Order, RAC shall produce any additional documents in its possession, custody or control reflecting policies, practices and procedures that it has not already produced, which are responsive to RFP Nos. 12, 18, 20, 21, 23, and 36-40, and shall serve supplemental written responses to these RFPs.

4. Within thirty (30) days from the date of this Order, RAC shall identify the five individuals most knowledgeable about the topics identified in RFP Nos. 45-48, namely purchasing merchandise to be offered for lease in California, pricing merchandise offered for lease in California, computing the Lessor's Cost of merchandise leased in California, and ensuring that pricing of merchandise in California complied with the Karnette Act.

5. Within thirty (30) days of the date of this Order, RAC shall produce all organizational charts currently in existence responsive to RFP Nos. 50, 51, and 53.

IT IS SO ORDERED.