Albert v. GLOBAL TELLINK CORP, MD, Memorandum Opinion and Order, Telephone Rates, 2025
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Case 8:20-cv-01936-LKG Document 492 Filed 10/31/25 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND ASHLEY ALBERT, et al., Plaintiffs, Civil Action No. 20-cv-01936-LKG vs. GLOBAL TEL*LINK CORP., et al., Defendants. JOINT STATUS REPORT REGARDING SECURUS DISCOVERY Plaintiffs and Securus submit this joint status report concerning the status of the production of communications and other discovery-related matters pursuant to the Court’s September 1, 2025 Order. Following the Court’s Order, the parties conferred about the full set of search terms to be run pursuant to the Order, including the “3Ci” search terms in light of the Court’s rejection of Plaintiffs’ proposed standalone “3Ci” search term. Plaintiffs also provided Securus with the list of governments for which they request production of Class Product contracts for 2011 and 2012. In addition, to facilitate the selection of AdvanceConnect Single Call (“ACSC”) contracts to be produced by Securus pursuant to the Court’s March 3, 2025 order, Plaintiffs reiterated their request (made previously on May 1, 2025) for Securus to identify the dates when each ACSC customer contracted for ACSC; Securus agreed to “provide this information within a reasonable timeframe.” On October 23, 2025, Securus produced what it represents to be available name and contact information for purchasers of Class Products to Plaintiffs. On that same date, Securus produced what it represents to be comprehensive commission history for its ACSC product from 2016 to Case 8:20-cv-01936-LKG Document 492 Filed 10/31/25 Page 2 of 8 2022 that also identified the agencies that contracted to use the ACSC product during that time period. Plaintiffs informed Securus of their view that this production does not comply with the Court’s March 3, 2025 order because it does not contain data “identifying the . . . cost to the consumer of an individual phone call” as the Court ordered. ECF No. 393. Securus is currently preparing a production related to the amounts consumers paid for ACSC calls during the same time period.1 Securus anticipates producing this information by the end of November 2025. Securus is also continuing to review documents covered by the Court’s September 1 Order and making rolling productions. For the Class Product contracts Plaintiffs identified on October 2, 2025, Securus anticipates producing the contracts by the end of November 2025. On October 15, the Court granted Plaintiffs’ motion for leave to amend their complaint to add two new named plaintiffs, and on October 29 Plaintiffs filed their Second Amended Complaint. On October 30, Plaintiffs sent Securus correspondence describing their position as to how the amendment affects the scope of discovery from Securus, including search terms, the lookback date for certain categories of discovery, and Class Product contracts for the years 201012. Securus is reviewing Plaintiffs’ position and will confer with Plaintiffs’ counsel about those issues. The parties have also conferred about the appropriate timing of production of discovery from Securus. On September 29, 2025, Securus’ counsel indicated that the timing for production of discovery should be governed by a scheduling order and suggested that Plaintiffs’ counsel propose one. On October 30, Plaintiffs sent Securus a proposed amended scheduling order proposing, inter alia, a deadline of January 22, 2026 for “Substantial Completion of Production of Securus states that this data is complex, involving significantly more transactions than the Class Products that were also billed and tracked in different ways, and Securus is still working to finalize the production. 1 2 Case 8:20-cv-01936-LKG Document 492 Filed 10/31/25 Page 3 of 8 Documents Other than Structured Data in Response to First Set of Requests for Production.” The parties intend to meet and confer regarding the proposed scheduling order and production dates. Securus’s view is that the proposed date of January 22, 2026 for substantial completion of documents does not provide sufficient time for Securus to complete its production of hundreds of thousands of documents, especially since Plaintiffs continue to propose changes to the search terms. As Plaintiffs admit, there are still search terms in dispute; just yesterday, Plaintiffs’ counsel reintroduced the 3Ci search term this Court has already rejected. Plaintiffs’ proposed date is not commensurate with the significantly longer time period Plaintiffs previously agreed to in the nowvacated scheduling order. Moreover, this date is not feasible because the Court has yet to lift the discovery stay, but would still bind Securus with respect to its yet to be propounded affirmative discovery. Right now, Plaintiffs are conducting unilateral discovery of Securus while Securus has been unable to pursue any discovery from Plaintiffs and others. Securus will work with Plaintiffs to propose a scheduling order, but the schedule needs to reflect the Court’s ruling on Securus’ request to lift the discovery stay. See ECF No. 484. Plaintiffs’ view is that the proposed scheduling order allows ample time for Securus to substantially complete its production. The parties are largely in agreement about the search terms, and there is no reason why Securus cannot begin reviewing and making rolling productions of custodial documents (and other documents) now.2 Moreover, this case has been pending for five years, and Plaintiffs brought their motion to compel discovery from Securus over a year ago. It is important that Securus produce the discovery it has been ordered to produce and has otherwise agreed to produce in an expeditious manner. Securus has already represented that it is making rolling productions of documents above, including custodial documents. 2 3 Case 8:20-cv-01936-LKG Document 492 Filed 10/31/25 Page 4 of 8 The parties will continue to meet and confer regarding the substantial completion deadline and will raise any proposed scheduling order or disputes with the Court. 4 Case 8:20-cv-01936-LKG October 31, 2025 Document 492 Filed 10/31/25 Page 5 of 8 Respectfully submitted, /s/ Robert A. Braun Benjamin D. Brown (pro hac vice) Robert A. Braun (D. Md. Bar No. 22059) COHEN MILSTEIN SELLERS & TOLL PLLC 1100 New York Ave. NW, 8th Fl. Washington, DC 20005 Tel: (202) 408-4600 Fax: (202) 408-4699 bbrown@cohenmilstein.com rbraun@cohenmilstein.com Christopher J. Bateman (pro hac vice) COHEN MILSTEIN SELLERS & TOLL PLLC 88 Pine St., 14th Fl. New York, NY 10005 Tel: (212) 838-7797 Fax: (212) 838-7745 cbateman@cohenmilstein.com George F. Farah (pro hac vice) Rebecca P. Chang (pro hac vice) Nicholas Jackson (pro hac vice) HANDLEY FARAH & ANDERSON PLLC 33 Irving Pl. New York, NY 10003 Tel: (212) 477-8090 Fax: (844) 300-1952 gfarah@hfajustice.com rchang@hfajustice.com njackson@hfajustice.com William H. Anderson (pro hac vice) HANDLEY FARAH & ANDERSON PLLC 5353 Manhattan Circle, Ste. 204 Boulder, CO 80303 Tel: (303) 800-9109 wanderson@hfajustice.com 5 Case 8:20-cv-01936-LKG Document 492 Filed 10/31/25 Page 6 of 8 Matthew K. Handley (D. Md. Bar No. 18636) HANDLEY FARAH & ANDERSON PLLC 1201 Connecticut Ave. NW, Ste. 200K Washington, DC 20036 Tel: (202) 559-2411 Fax: (844) 300-1952 mhandley@hfajustice.com Simon Wiener (pro hac vice) HANDLEY FARAH & ANDERSON PLLC 68 Harrison Ave., Ste. 604 Boston, MA 02111 Tel: (202) 921-4567 Fax: (844) 300-1952 swiener@hfajusstice.com Interim Co-Lead Counsel for Plaintiffs and the Proposed Class /s/ Amy Brown Doolittle Amy Brown Doolittle (Bar. No 15455) Gabriel Colwell (pro hac vice) Jesse Taylor (pro hac vice) SQUIRE PATTON BOGGS (US) LLP 2250 M Street, N.W. Washington, D.C. 20037 Telephone: (202) 457-6000 Facsimile: (202) 457-6315 amy.doolittle@squirepb.com gabriel.colwell@squirepb.com jesse.taylor@squirepb.com Counsel for Securus Technologies, LLC 6 Case 8:20-cv-01936-LKG Document 492 7 Filed 10/31/25 Page 7 of 8 Case 8:20-cv-01936-LKG Document 492 Filed 10/31/25 Page 8 of 8 CERTIFICATE OF SERVICE I hereby certify that on October 31, 2025, I electronically filed the Joint Status Report Regarding Securus Discovery with the Clerk of the Court using the ECF, who in turn sent notice to counsel of record. Dated: October 31, 2025 /s/ Robert A. Braun Robert A. Braun 8