Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 115 of 123 PageID: 4298 7-ELEVEN, INC. v. KARAMJEET SODHI, et al DESIGNATED REPRESENTATIVE(S) TOPICS OF INQUIRY SCHEDULE “A” Franchise Agreements. Defendants’ Policies, procedures and/or guidelines regarding 7-Eleven’s Retail Information system. Policies, procedures and/or guidelines regarding 7-Eleven’s Point of Sale system. Default and/or deficiency notices, including Letter of Notifications issued to (“LON”) Defendants, individually and/or collectively. Operations and training manuals, policy statements, and directives relating to franchisees in the Zone. “Penn/Jersey” Training of franchisees, Field Consultants, Market Managers, and Zone Leaders from 2008 to present. Policies, procedures and/or guidelines regarding 7-Eleven’s inventory audits of franchised stores. All audits, announced and unannounced, of Stores, including but not limited Defendants’ to, communications with Defendants, employees, and audit procedures from 2008 to present. The Declaration of 7-Eleven employee James Passarella. The Certification of former 7-Eleven employee Kurt McCord. The November 17, 2011 interview with Defendant Karamjit Sodhi. Policies, procedures and/or guidelines regarding 7-Eleven’s Money Order system. Policies, procedures and/or guidelines regarding 7-Eleven’s franchisee employment and labor practices investigations, including but not limited to, any and all investigations initiated against Defendants. Communications and interviews of former employee Amarjit Kaur. Defendants’ The notebooks produced by former employee Amarjit Kaur during the January 26, 2012 meeting with 7-Eleven employee James Passarella. if any, in investigations relating to stores. Joseph DePinto’s involvement, Defendants’ Mark involvement, if any, in investigations relating to stores. Stinde’s Defendants’
Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 115 of 123 PageID: 4298 7-ELEVEN, INC. v. KARAMJEET SODHI, et al DESIGNATED REPRESENTATIVE(S) TOPICS OF INQUIRY SCHEDULE “A” Defendants’ Franchise Agreements. Policies, procedures and/or guidelines regarding 7-Eleven’s Retail Information system. Policies, procedures and/or guidelines regarding 7-Eleven’s Point of Sale system. Default and/or deficiency notices, including Letter of Notifications (“LON”) issued to Defendants, individually and/or collectively. Operations and training manuals, policy statements, and directives relating to franchisees in the “Penn/Jersey” Zone. Training of franchisees, Field Consultants, Market Managers, and Zone Leaders from 2008 to present. Policies, procedures and/or guidelines regarding 7-Eleven’s inventory audits of franchised stores. All audits, announced and unannounced, of Defendants’ Stores, including but not limited to, communications with Defendants, employees, and audit procedures from 2008 to present. The Declaration of 7-Eleven employee James Passarella. The Certification of former 7-Eleven employee Kurt McCord. The November 17, 2011 interview with Defendant Karamjit Sodhi. Policies, procedures and/or guidelines regarding 7-Eleven’s Money Order system. Policies, procedures and/or guidelines regarding 7-Eleven’s franchisee employment and labor practices investigations, including but not limited to, any and all investigations initiated against Defendants. Communications and interviews of Defendants’ former employee Amarjit Kaur. The notebooks produced by former employee Amarjit Kaur during the January 26, 2012 meeting with 7-Eleven employee James Passarella. Joseph DePinto’s involvement, if any, in investigations relating to Defendants’ stores. Mark Stinde’s involvement, if any, in investigations relating to Defendants’ stores.
212-Letter-of-Gerald-A-Marks-in-Response-to-Letter-Seeking-Stay-1-1-29-15.docx