Paschini

I. BACKGROUND

25 In his complaint, Plaintiff alleges that he was employed as WaveCrest’s Chief 26 Revenue Officer from 2015 to 2017. ECF No. 1-1 at ¶ 6. Based on his employment 27 contracts, Plaintiff alleges that he was due certain commissions and bonuses that would 28 be calculated from WaveCrest’s actual gross profit and a bonus structure based on achievement of certain objectives and deliverables. Id. On January 12, 2018, prior to WaveCrest paying Plaintiff any of the commissions and bonuses, Plaintiff alleges that he was terminated without cause. Id. at ¶ 7. Plaintiff alleges that WaveCrest then adjusted its actual gross profit down by over a million dollars, specifically by including a “Provision of Legal Fees” in the amount of $540,000 and a “Provision for Restructuring” in the amount of $708,000. Id. at ¶ 8. Plaintiff alleges that WaveCrest made this adjustment to eliminate any commissions and bonuses that would have been due him, and that WaveCrest has not paid him any to date. Id. The present motion relates to discovery requests propounded in Plaintiff’s First Set of Interrogatories and First Set of Requests for…