The opinion of the court was delivered by: John M. Facciola United States Magistrate Judge
Plaintiff alleges that defendants discriminated against her on the basis of her race (African American), gender (female), age (then 67), and perceived physical disability (degenerative arthritis). Specifically, plaintiff claims that after working for four years as a Human Resources Consultant in Amtrak's *fn1 Office of Workplace Development, Human Resources Department, the company then rejected her application for the position of Manager of Employee Services and later terminated her. Currently pending and ready for resolution are three discovery motions: 1) Plaintiff's Motion to Compel Defendants' Discovery Responses, 2) plaintiff's Motion to Quash or, in the Alternative, for a Protective Order, and 3) Plaintiff's Motion to Allow Additional Depositions.
Plaintiff's three motions raise eight topics for discussion: *fn2
1. The duties of Paul Bello, an employee who survived the restructuring that resulted in plaintiff's termination.
2. The consequences, if any, resulting from previous Amtrak restructurings, to
Amtrak employees who are members of protected classes. 3. Amtrak's hiring and firing of other members of protected classes during plaintiff's employment.
4. All other complaints of discrimination, if any, against Amtrak during the period of plaintiff's employment.
5. The availability of information regarding a prior class action, in which plaintiff was a class member, filed in this court.
6. Whether certain materials produced by a consultant from Amtrak are protected by the attorney-client or work product privileges.
7. Whether the discovery cutoff date bars any additional discovery.
8. Whether plaintiff should be permitted to take two additional depositions.
I. Plaintiff's Motion to Compel Defendants' Discovery Responses
A. The Duties of Paul Bello and Previous "Restructurings"
In 1997, Congress ordered that Amtrak, then in financial crisis, *fn3 reduce management costs and increase employee productivity. The Amtrak Reform and Accountability Act of 1997, Pub. L. No. 105-134, 111 Stat. 2571 (1997).
Amtrak's defense in this case is based on the mandates of this Act:
At the end of 1999, in an effort to comply with this mandate and to increase responsiveness to management development and create consistency in all training programs, defendants decided to outsource the supervisory and leadership programs offered by the Workforce Development Office. Because plaintiff's main focus was the delivery of these programs, defendants' decision resulted in the elimination of her position. Plaintiff was terminated on January 7, 2000: Amtrak used the resources provided by the American Management to satisfy its supervisory/leadership development needs. Defendants' Opposition to Plaintiff's Motion to Compel ("Defs. Opp." at 3).
Plaintiff claims that information about how other employees, not of plaintiff's race, sex, age, and disability, were treated during previous restructuring efforts by Amtrak between 1996 and 1999 is relevant to her claim of discrimination. Hence, in interrogatories 6 and 7, she seeks a description of any restructuring of Amtrak's Human Resources department "between 1996 and the present" as well as the identification of any employee affected by any prior restructuring, including his or her name, position, race, gender, age, disability, and the way in which he or she was affected by the restructuring.
Defendants provided information as to a 1998 "comprehensive review of all corporate services" that led to the elimination of the positions of three named persons who functioned as "HR consultants" and the reassignment of four other named "HR consultants." Defendants then described the 1999 PricewaterhouseCoopers organizational assessment of the Human Resources Department that led to the decision to outsource the "supervisory/leadership programs" and the resulting termination of plaintiff. Defendant's Supplemental Responses to Plaintiff's First Set of Interrogatories at 4-5. Defendants refused, however, to provide any information about any employees affected by the earlier restructuring, stating that the requests were overly broad and unduly burdensome. *fn4 The defendants also claimed that disclosing such information would violate the ...