SA Music LLC v. Apple, Inc

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 6 Case Nos. 20-cv-02146-WHO (JSC) SA MUSIC LLC, et al., 20-cv-02794-EMC (JSC) Plaintiffs, 20-cv-02965-JSW (JSC) 8 v. ORDER RE: DEPOSITION ERRATA DISCOVERY DISPUTE

APPLE, INC, et al., Re: Dkt. No. 82 Defendants.

12 Apple moves to strike deposition errata submitted by Julia Riva and Ray Henderson Music Co. Inc. following their depositions. (Dkt. No. 82.) After carefully considering the parties’ submission, the Court STRIKES the challenged deposition errata.

Federal Rule of Civil Procedure 30(e), which governs review of deposition transcripts and changes thereto, permits corrections in “form or substance” of deposition testimony under certain circumstances, provided that procedural requirements are met. However, a deposition is not a take home examination. Thus, in the Ninth Circuit, Rule 30(e) deposition changes are subject to the “sham …