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Kannan v. Apple Inc.

United States District Court, N.D. California

September 25, 2019

RAJA KANNAN, Plaintiff,
v.
APPLE INC., Defendant.

          ORDER RE DISCOVERY DISPUTES RE: DKT. NOS. 108, 110, 112, 113, 114, 115

          VIRGINIA K. DEMARCHI UNITED STATES MAGISTRATE JUDGE

         The parties in this case have asked the Court to resolve a number of discovery disputes. Dkt Nos. 108, 110, 112, 113, 114, 115. The Court held a hearing on all disputes on September 24, 2019. Dkt. No. 117. For the reasons stated on the record, and as further described below, the Court resolves the disputes as follows:

         I. MR. KANNAN’S MOTIONS

         A. Dkt. No. 108 (Ex. 1) and Dkt. No. 114

         Plaintiff Raja Kannan moves to compel Apple’s compliance with the Court’s prior discovery order issued on July 11, 2019 (Dkt. No. 105). Mr. Kannan seeks sanctions for Apple’s alleged non-compliance. Apple contends that it has complied with the Court’s prior order.

         This dispute arises principally from a disagreement between the parties regarding the scope of the document requests at issue in the Court’s July 11 order. Mr. Kannan’s document requests are neither as comprehensive nor as clear as he believes them to be, and Apple’s document production is not as complete as it should have been. The Court resolves the dispute as follows:

1. For each of Mr. Kotni’s employees[1] during the relevant time period[2], Apple must produce documents containing information similar to that found in the “options and awards summary” produced with respect to Mr. Kannan at APL-KANNAN00000384.
2. For each of Mr. Kotni’s employees during the relevant time period, Apple must produce bi-weekly pay statements with redactions that are no more extensive than the redactions reflected in the year-end pay statements Apple has already produced, such as APL-KANNAN00004010.
3. Apple must complete its production of compensation calibration sheets and compensation planning guidelines applicable to Mr. Kotni’s employees during the relevant time period, including for the years 2011 and 2012.
4. For each of Mr. Kotni’s employees during the relevant time period, Apple must produce documents sufficient to show the contractors or employees who reported to each such employee of Mr. Kotni.
5. For each of Mr. Kotni’s employees during the relevant time period, Apple must produce documents sufficient to show the job level of that employee, his or her promotion to a different job level, and the effective date of any such change in job level. The Court understands that Apple believes it has already produced this information. If, upon further review, Apple concludes that its production of this information is not complete, Apple may provide this information in the form of spreadsheet reflecting the output of a database query.
6. To the extent Apple maintains a database or other repository of information that may be queried to provide a report(s) or spreadsheet(s) showing, for each of Mr. Kotni’s employees during the relevant time period, the employee’s compensation, stock awards, bonuses, and dividends, Apple must produce that information in report or spreadsheet form. Apple need only produce the information that is kept in the ordinary course of business. Apple is not required to manually create a report or spreadsheet from its records. Apple must produce these documents no later than October 1, 2019. If Apple cannot comply with this deadline with respect to item 6, above, it shall so inform Mr. Kannan and the Court, and it shall provide a date by which it will complete its production. The Court concludes that no sanctions are warranted at this time.

         B. Dkt. No. 108 (Ex. 2) and Dkt. No. 115

         Mr. Kannan moves to compel a Rule 30(b)(6) deposition of Apple on 27 topics. Mr. Kannan’s motion is granted in part and denied in part as follows:

         Apple shall designate and prepare one or more witnesses to testify as to Topics Nos. 1-17 and 21-24. As to all topics that concern Mr. Kotni’s employees, the relevant time period is January 1, 2011 through December 31, 2018. As to all topics that concern Mr. Kannan, the relevant time period is the time period during which he worked for Mr. Kotni, except that as to Topics Nos. 1 and 6, the relevant time period encompasses the period just prior to Mr. Kannan’s transfer to his position under Mr. Kotni during which Apple allegedly canceled Mr. Kannan’s bonus and/or stock award. Topic No. 9 is further limited to the bonus guidelines applicable to contributor level 4, contributor level 5, and manager level 1 employees.

         Apple shall designate and prepare one or more witnesses to testify as to Topic No. 18, but only with regard to the contractors or employees who reported to each of Mr. ...


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