Judge Boulware held a hearing in his courtroom last week to discuss the plaintiffs in the Kajan Johnson case Motion to Compel Documents from defendant Endeavor. While Judge Boulware held off on making major rulings he required Endeavor to respond to certain discovery which they had rebuffed.
After the initial refusal, the court rules require a “meet-and-confer” process in which the parties have to have a conference to discuss their dispute and attempt to come to a resolution before going to the Judge for an intervention. These conferences are commemorated in letters between attorneys providing a recap on what transpired.
On January 23rd attorneys for defendants Zuffa and Endeavor wrote plaintiffs maintaining its position that most (if not all) of the fact discovery responses and documents had been provided in the Le lawsuit.

“…we continue to be concerned about the overbroad and disproportionately burdensome nature of Plaintiffs’ 71 RFPs [Requests for Production] to Zuffa.” Jessica Phillips, the attorney at the law firm of Paul Weiss who represents Zuffa wrote. “Plaintiffs are not entitled to a fishing expedition untethered to proportionality principles or the issues actually being litigated in this case.”
Phillips notes that defendants produced “over 1.5 million pages of documents” and agreed to provide a “crosswalk” table identifying which Le Bates numbers correspond to the Johnson Bates numbers. In addition, Phillips notes that it has produced over 87,000 new pages in the Johnson case.
Phillips responded to each of the requests from Plaintiffs that her client found duplicative, overbroad and not relevant to the current case. In addition, the two sides argued over the timeline for this lawsuit. But, Endeavor agreed to a timeframe to produce documents from July 1, 2015 to June 30, 2017.

More specifically, Phillips provides Endeavor’s position to the specific requests below.





Attorney for plaintiffs, Michael Dell’Angelo sent a letter on February 3, 2025 regarding “Endeavor’s continuing refusal to respond to or engage in discovery related to Endeavor’s role in the conduct giving rise to Plaintiffs’ claims.” The letter was in response to Endeavor’s position that it would not respond to discovery from plaintiffs until the Court had ruled on its Motion to Dismiss. A plausible position from the defendants considering that you do not want to expend the time, effort and money in discovery requests that you may not be obliged to provide Moreover, Endeavor does not want to disclose any information of its company that it has to. If you are plaintiffs, you certainly want to continue to conduct discovery as there is a cutoff that the parties have to comply with and if they wait, they may be shut out.

If the Court does not grant Endeavor’s Motion to Dismiss, there is no prospect the Court would extend the deadline to conduct discovery. Thus, plaintiffs must show urgency in getting it done despite Endeavor’s position that it may be futile.
Three days later, on February 6th, Dell’Angelo sent another letter to defendants which summed up a “meet-and-confer video conference” with Endeavor’s counsel. In the video conference, Endeavor’s attorney, Joseph Axelrad, maintained the continued position that it would wait until the Court ruled on its Motion to Dismiss. “Defendants confirmed that they will not change their position on discovery, but disagreed that the parties are at an impasse.”

A court hearing was held on June 3rd to hammer out these discovery issues. The key issues discussed also included a Motion to Deny Class Certification.
Judge Boulware deferred the big question of denying class certification for another time pending a response from plaintiffs
In a minute order, Judge Boulware granted in part and denied in part Plaintiffs’ Motion to Compel discovery responses.
For those interested on the Court ruling in the Kajan Johnson lawsuit last week, Judge Boulware punted on most rulings. No ruling on Class Certification as that question is being deferred. Another status conference will be held 08/28/25 #UFC #Zuffa
— Jason Cruz (@dilletaunt.bsky.social) June 9, 2025 at 11:40 AM
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Judge Boulware denied plaintiffs’ Motion to Compel responses to Request for Production of documents number 18, 19, 22, 23, 28, 29, 33, 34, 42, 79 and 80.
Judge Boulware granted plaintiffs’ Motion to Compel for Request for Production of documents numbers 1-17, 20-21, 24-27, 30-32, 35-41, 43-78 and 81-94.
The requests mainly pertain to most of what Philips object to which relate to Endeavor’s potential inclusion in this lawsuit.
The deadline to produce the documents is August 17, 2025. Judge Boulware also stated that these request also include Zuffa and TKO.
He also ordered a further status conference on the Johnson, Cirkunov and Davis lawsuits on August 28, 2025.
MPO will continue to follow.

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