United States Chief Magistrate Judge Maria-Elena James is on a roll with the class member contact information discovery orders. In Currie-White v. Blockbuster, Inc., 2010 WL 1526314 (N.D.Cal. Apr 15, 2010), Magistrate Judge James Ordered defendant to produce class member contact information, subject to certain modifications to a pre-existing protective order in the case. The interesting additional tidbit in this case is that it is described as a "class action against Defendant under the Labor Code Private Attorneys General Act of 2004, Cal. Labor Code §§ 2698, et seq." Moving to certify PAGA-based penalty claims certainly eliminates all the uncertainty about PAGA-based representative actions.