Discovery, Investigation, and Research Sample Clauses

Discovery, Investigation, and Research. Plaintiffs’ Attorneys conducted an extensive investigation into the facts before and during the prosecution of the Action. This discovery and investigation has included among other things, (a) multiple meetings and conferences with first, the lead Named Plaintiff, Xxxxx Xxxxxx, for several weeks or months before the filing of the Action, (b) inspection and analysis of documents produced by Named Plaintiff Xxxxxx; analysis of the legal positions which could be taken by Defendant; (d) investigation into the viability of class treatment of the claims, and which claims would be suitable for class treatment; (e) investigation and discussion over other potential Named Plaintiffs and who would be suitable for such a responsibility; analysis of potential class-wide damages; (f) research of the applicable law with respect to the potential claims and potential defenses thereto; (g) inspecting and analyzing millions of lines of electronic data produced by Defendant during discovery and prior to mediation.

Discovery, Investigation, and Research. Class Counsel conducted an investigation into the facts during the prosecution of the Action. This discovery and investigation has included, among other things (a) multiple meetings and conferences with the Class Representatives; (b) inspection and analysis of documents produced by the Class Representatives and Defendant; (c) deposing eleven of Defendant’s managers, defending the depositions of all Class Representatives and six putative class members, and attending the depositions of four third parties, (d) analysis of the legal positions taken by Defendant; (e) investigation into the viability of class treatment of the claims asserted; (f) extensive analysis of class-wide damages, including the analysis of millions of lines of data related to the delivery activities of the Carriers throughout the class period in the state of California; (g) research of the applicable law with respect to the claims and potential defenses thereto; (h) serving and responding to discovery requests; (i) conducting wide-ranging electronic discovery which resulted in the production and review of hundreds of thousands of documents and reports; and (j) participating in two full-day mediation sessions. The Class Representatives have vigorously prosecuted this case, and Defendant has vigorously contested it. The Parties have engaged in sufficient investigation and discovery to assess the relative merits of the claims and of Defendant’s defenses available to them.

Discovery, Investigation, and Research. In prosecution of the Action and in pursuit of a fair and reasonable settlement consistent with the best interests of the Class, Class Counsel has conducted extensive discovery and investigation relating to the Claims at issue in the Action. This discovery, investigation, and prosecution has included, among other things: (a) holding multiple meetings with Plaintiffs via telephone, zoom, and in-person;