Davis (Ps) are African-American and Latino employees who worked at Precoat’s (D) Chicago plant. They allege they have been exposed to a hostile work environment. They allege they are subjected to racially insulting and derogatory remarks by D’s management level employees. Ps also allege that D has discriminated against them in terms of entry-level placement, work assignments, promotions, and discipline and that D retaliated against them for complaining about those practices. Ps noticed D for discovery over a narrow period of time-related to all racial discriminatory complaints at the plant were Ps worked. D refused to answer, and P had to motion to compel.