Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 29 of 123 PageID: 4212 The shall mean Defendants Karamjeet Sodhi, et al., and each of their “Defendants” respective past and/or present officers, directors, agents, servants, representatives, employees, independent contractors, attorneys, consultants, experts, investigators, predecessors, successors, parents, subsidiaries, affiliates, and any other person or entity acting or purporting to act on behalf of Defendants. shall mean any of the six (6) franchise locations owned and “Sodhi’s Stores” operated by Defendant Sodhi. shall mean the original complaint in this matter filed by 7-Eleven, Inc. “Complaint” on June 15, 2013. shall mean the amended pleading filed by 7-Eleven, Inc. on “Amended Complaint” June 26, 2013. shall mean the investigation conducted by Plaintiff in connection with “Investigation” Defendant six stores that is the subject of this dispute. Sodhi’s or shall mean alleged current employer, Amarjit “Amarjit Kaur” “Kaur” Plaintiff’s Kaur, who filed Declarations in connection with this matter. or as used herein should be construed in the broadest “Document” “documents” possible sense and refers to any printed, written, taped, recorded, photographed, video recorded, graphic, computerized, electronically stored, or other tangible matter, from whatever source, however produced or reproduced, whether in draft or otherwise. This includes, but is not limited to, notes, correspondence, e-mails, memoranda, messages, outlines and/or proposals, and any other items or things within the scope of Rule 34 of the Federal Rules of Civil Procedure.
Case 1:13-cv-04578-RMB-JS Document 212 Filed 01/29/15 Page 29 of 123 PageID: 4212 The “Defendants” shall mean Defendants Karamjeet Sodhi, et al., and each of their respective past and/or present officers, directors, agents, servants, representatives, employees, independent contractors, attorneys, consultants, experts, investigators, predecessors, successors, parents, subsidiaries, affiliates, and any other person or entity acting or purporting to act on behalf of Defendants. “Sodhi’s Stores” shall mean any of the six (6) franchise locations owned and operated by Defendant Sodhi. “Complaint” shall mean the original complaint in this matter filed by 7-Eleven, Inc. on June 15, 2013. “Amended Complaint” shall mean the amended pleading filed by 7-Eleven, Inc. on June 26, 2013. “Investigation” shall mean the investigation conducted by Plaintiff in connection with Defendant Sodhi’s six stores that is the subject of this dispute. “Amarjit Kaur” or “Kaur” shall mean Plaintiff’s alleged current employer, Amarjit Kaur, who filed Declarations in connection with this matter. “Document” or “documents” as used herein should be construed in the broadest possible sense and refers to any printed, written, taped, recorded, photographed, video recorded, graphic, computerized, electronically stored, or other tangible matter, from whatever source, however produced or reproduced, whether in draft or otherwise. This includes, but is not limited to, notes, correspondence, e-mails, memoranda, messages, outlines and/or proposals, and any other items or things within the scope of Rule 34 of the Federal Rules of Civil Procedure.
212-Letter-of-Gerald-A-Marks-in-Response-to-Letter-Seeking-Stay-1-1-29-15.docx