In re Sandisk SSDS Litigation

District Court, N.D. California·Decided August 11, 2025·No. 3:23-cv-04152·Unknown

Opinion

1 2 5 6 In re SANDISK SSDs LITIGATION. Case No. 23-cv-04152-RFL (LJC)

7 ORDER REGARDING MOTION TO REOPEN DEPOSITIONS, LETTERS 8 REGARDING DEPOSITION OF MATT WHITE, AND MOTIONS TO FILE Re: Dkt. Nos. 174, 175, 188, 191, 195, 196 10

11 A. Motion to Reopen Discovery 12 Plaintiffs move to reopen fact discovery to reopen three depositions of Defendants’ 13 employees in light of Defendants’ belated production of documents that Defendants had 14 previously designated as privileged. ECF No. 174. Judge Lin referred the question of “whether 15 the witnesses should be re-deposed” to the undersigned magistrate judge, and indicated that 16 “discovery may be reopened for the limited purpose of accommodating those depositions” if the 17 undersigned found them to be warranted. ECF No. 180. 18 There is no dispute that Defendants withdrew their privilege designations as to the vast 19 majority of documents in dispute, and produced those documents after the witnesses at issue were 20 deposed. Defendants also failed initially to provide a privilege log as required by Rule 26(b)(5) of 21 the Federal Rules of Civil Procedure. And of the relatively small number of documents for which 22 the parties were not able to resolve their privilege disputes, this Court has found that most of those 23 also are not privileged (at least not in their entirety) and should have been produced (at least with 24 redactions). ECF No. 198. 25 Defendants dispute whether the documents at issue include sufficient relevant information, 26 not previously known to Plaintiffs, to warrant reopening the depositions of these particular 27 employees. But where Defendants have brought this situation on themselves by withholding 1 Plaintiffs’ assessment of the potential relevance of the documents. Under Rule 30 of the Federal 2 Rules of Civil Procedure, “[t]he court must allow additional time [for depositions] consistent with 3 Rule 26(b)(1) and (2) if needed to fairly examine the deponent or if the deponent, another person, 4 or any other circumstance impedes or delays the examination.” Fed. R. Civ. P. 30(d)(1). 5 Defendants impeded these examinations by failing to produce documents subject to discovery 6 prior to the depositions. The Court is inclined to grant Plaintiffs the opportunity they were 7 previously denied to question the witnesses about those documents, at least some of which relate 8 specifically to each of these witnesses. 9 This Order is intended to redress Defendants’ previous failure to produce documents, not 10 to grant Plaintiffs a complete do-over of previous depositions. To that end, the reopened 11 depositions shall be limited to questions pertaining to documents produced after the original 12 deposition,1 questions pertaining to testimony from other witnesses’ reopened depositions, and 13 reasonable follow-up questions to the witnesses’ responses to those questions. Plaintiffs’ failure 14 to abide by those limits shall not be grounds to instruct a witness not to answer or suspend a 15 deposition, but after the deposition has concluded Defendants may seek any relief that they believe 16 appropriate for a substantial violation of this Order, potentially including the exclusion of 17 evidence or attorneys’ fees for wasted time. 18 The Court further notes that while the parties dispute the likely effect of such reopened 19 deposition on the case schedule, see ECF No. 187, it appears feasible to complete three reopened 20 depositions (or four, including Matthew White as discussed below) for the limited purpose 21 allowed by this Order without altering the October 14, 2025 deadline for class certification and 22 Rule 702 motions, particularly if the documents at issue are of as limited relevance as Defendants 23 contend. This Court expects that the parties will be able to supplement their expert reports to 24

25 1 It is not clear if any other documents were produced after these depositions beyond what was at issue in the parties’ disputes over Defendants’ privilege assertions. If other documents were also 26 produced after the depositions, Plaintiffs may also ask about any such documents. Defendants may not be to blame for other document productions occurring after the depositions, but when the 27 depositions will be reopened anyway to account for Defendants’ unwarranted privilege 1 account for new testimony without materially affecting the case schedule. That said, if any party 2 believes that the schedule set by Judge Lin should be altered, that is a matter to be addressed to 3 Judge Lin. 4 B. Deposition of Matthew White 5 The parties previously filed a joint letter raising disputes over instructions not to answer 6 and other purported misconduct during Plaintiffs’ deposition of Defendant SanDisk LLC’s Rule 7 30(b)(6) witness Dr. Matthew White. ECF No. 164. Plaintiff sought to reopen the deposition, id. 8 at 1, and Defendants “agreed to produce him for deposition again as Defendants’ Rule 30(b)(6) 9 designee for the limited basis that Plaintiffs may obtain responses to questions (as well as 10 responses to natural follow-up questions to Mr. White’s responses) that defense counsel had 11 instructed Mr. White not to answer because they deemed the questions to be outside the scope of” 12 the deposition notice. Id. at 3–4 n.1. The Court acknowledged Defendants’ agreement as to those 13 questions, ECF No. 165 at 1, and held in response to the parties disputes over instructions not to 14 answer based on attorney-client privilege that “Plaintiffs may ask White questions going to 15 whether attorneys provided SanDisk employees with business advice (including public relations 16 advice) as distinct from legal advice,” and “about the substance of those communications” if so, 17 id. at 3. The Court also mentioned in a footnote that “instructions not to answer for other reasons 18 unrelated to privilege are also generally improper,” citing an instance where defense counsel 19 instructed White not to answer a question on the basis that he had already answered the same 20 question. Id. at 1 n.1. 21 The parties now dispute whether the reopened deposition should be limited to the issues 22 addressed in that Order. “Defendants maintain that the scope is limited to the issues articulated in 23 [the] May 22, 2025, order, while Plaintiffs believe that the reopened deposition is limited to the 24 list of Rule 30(b)(6) topics Dr. White was previously designated to testify to on behalf of 25 SanDisk.” ECF No. 195. 26 Plaintiffs’ original arguments for reopening this deposition identified specific instances of 27 purportedly unwarranted instructions not to answer and other purported misconduct. ECF No, 164 1 Plaintiffs as to most of their arguments. ECF No. 165. But Plaintiffs did not argue specifically at 2 the time that the deposition misconduct at issue prevented Plaintiffs from effectively deposing 3 White beyond the particular lines of questioning addressed in the parties’ joint letter. Plaintiffs 4 now argue that “the deposition was cut short after a few hours,” and that they were unable to 5 obtain probative testimony even beyond the specific issues addressed in the previous Order. ECF 6 No. 195 at 4. But Plaintiffs raised no such argument in the previous joint letter, and the transcript 7 excerpt submitted with the present letter indicates that Plaintiffs’ counsel chose to end the 8 deposition:

9 MR. BOGDANOVICH: What’s the -- yeah, I don’t think I have any more questions for today. 10 I -- Counsel, just while I’m on the record, we’re reserving the right to 11 reopen this deposition, given the many privilege objections.

12 But, otherwise, based on what you’ve allowed me to ask of the witness today, I have no further questions. 13 14 ECF No. 195-1 at 3 (Tr. at 196:10–17).

Free access — add to your briefcase to read the full text and ask questions with AI

In re Sandisk SSDS Litigation, (N.D. Cal. 2025).

In re Sandisk SSDS Litigation (In re Sandisk SSDS Litigation) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Center for Auto Safety v. Chrysler Group, LLC
809 F.3d 1092 (Ninth Circuit, 2016)