People Centre, INC [D/B/A Rippling] and Anor v O'Brien and Ors [No. 3] (Approved)

                  This judgment concerns an application by the fourth named defendant Deel Inc ('Deel') by notice of motion of 28 July 2025. The motion was one of a number of applications brought by Deel in respect of the conduct of the present proceedings, which motions were heard by the court on 2-5 December 2025.

                  The respective solicitors engaged in relation to the various motions in order to cut down the areas of disagreement. Much of the correspondence concerned the extent to which a motion by which the plaintiffs sought redactions to documents to be produced ('the redactions motion') could be agreed.

                  The application the subject of this judgment was initiated by notice of motion on 28 July 2025. The motion ('the inspection motion') sought further and better particulars of the plaintiffs' claim; by the date of the hearing, that issue was resolved. The sole relief sought by Deel at the hearing was at para. 3 of the notice of motion:

"An Order pursuant to Order 31, rule 18 RSC directing the Plaintiffs to produce for inspection by the Fourth-Named Defendant a full and proper copy of the Termination Agreement entered into by the Plaintiffs and the First-Named Defendant dated 27 March 2025 (referred to at �49, Amended Statement of Claim and at ��21-22, affidavit of Vanessa Wu sworn on 1 April 2025) sought at paragraph 25(vi) of the Notice for Particulars and also at paragraph (a) of the Notice to Produce of the Fourth-Named Defendant dated 8 July 2025;" [Emphasis in original].

                  During the hearing of the various motions, the respective solicitors continued to see if the motions could be resolved. By letter of 1 December 2025, the plaintiffs' solicitors, referring to the third category of documents in the redactions motion, offered the following: