In re SanDisk SSDs Litigation

Summary

The United States District Court for the Northern District of California resolves joint discovery letters concerning depositions in the SanDisk SSDs litigation. The court grants a protective order barring the deposition of SanDisk CEO David Goeckeler for lack of demonstrated relevance and undue burden, but orders Defendants to produce Lisa Neitzel and Lynne Cox for depositions by May 31, 2025.

Holdings

1. Plaintiffs could not depose Goeckeler because they offered only speculation concerning his involvement in or particularly relevant knowledge of the alleged product defects and related disclosure decisions, while the burden of deposing the company's chief executive outweighed the likely relevance of his testimony.
2. Seven days' notice was not unreasonable on its face where the depositions sought no document production, the witnesses and counsel were not shown to be unavailable, and the proposed date fell within the fact-discovery period.
3. The standing-order provision stating that proposed case schedules should include a last date to notice depositions at least 30 days before the close of fact discovery did not itself establish an enforceable deadline in this case.

Questions Presented

1. Whether Plaintiffs had shown sufficient involvement or relevant knowledge to justify deposing SanDisk CEO David Goeckeler despite the burden associated with an apex deposition.
2. Whether seven days' notice for the depositions of Lisa Neitzel and Lynne Cox was unreasonable under Federal Rule of Civil Procedure 30(b)(1).
3. Whether a standing-order provision stating that case schedules should include a deposition-notice date at least 30 days before the close of fact discovery created an enforceable deadline in this case.

Disposition

other