In re Sandisk SSDS Litigation
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 6 In re SANDISK SSDs LITIGATION. Case No. 23-cv-04152-RFL (LJC)
ORDER RESOLVING JOINT
DISCOVERY LETTERS REGARDING
DEPOSITIONS
10 Re: Dkt. Nos. 152, 156
A. Deposition of David Goeckeler The Court previously struck a joint letter regarding Plaintiffs’ request to depose SanDisk CEO David Goeckeler and Defendants’ arguments that Plaintiffs had not shown sufficient cause to depose that “apex” witness. ECF No. 150. In doing so, the Court provided guidance for any renewed letter on that topic. First, the Court advised the parties that “this Court does not take a formalistic approach to the ‘apex doctrine’ imposing strict requirements of exhaustion or unique knowledge before such a deposition will be permitted, although such considerations may be relevant factors,” and that the “Court recognizes that in typical, ordinary circumstances deposing a large company’s chief executive imposes a substantial burden.” Id. at 1–2 (citing In re Uber Techs., Inc.…