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Posts by Matt Siegel

it's RFK this time but it's indistinguishable from fauci, walensky, biden, wen, or any of the other ghouls whose names have graciously escaped me at the moment who have helped normalize the abandonment of people like me to this ongoing pandemic

42 minutes ago 4 4 1 0

I was telling some friends today that it's amazing we haven't all died from stress... and realized that's survivor bias talking.

Plenty of people are definitely not surviving the stress.

But we muddle through

1 hour ago 59 5 1 0

the guy is a mass murderer

1 hour ago 3 0 0 0

Oh this would be my jam!!

1 hour ago 3 1 0 0

hahaha 🍑

1 hour ago 1 0 1 0

:D 🤞🤞

1 hour ago 1 0 0 0

if you have any amount of money to help one of the most upstanding and diligent people i know (ashley) continue making headway against the illegal actions of a $4 trillion company (apple), please chip in!

reposts appreciated

www.ashleygjovik.com/donate.html

1 hour ago 3 2 1 0
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On April 14, 2026, Judge Chen extended Plaintiff’s deadline to take the deposition of
Apple, Inc.’s corporate witness, pursuant to Federal Rule of Civil Procedure 30(b)(6), to May 14,
2026. (Dkt. No. 352 at 4.) Judge Chen ordered the parties to meet and confer regarding the
deposition topics, and ordered them to file a joint discovery letter before the undersigned should
they be unable to reach an agreement. Id. at 4-5.
During the parties’ meet and confer efforts, Plaintiff agreed to narrow the topics from 14 to
10. (Joint Letter, Dkt. No. 356.) They could not, however, agree on the remaining 10 deposition
topics and filed the instant joint discovery letter on April 21, 2026. Id.
Plaintiff contends that she seeks information regarding the remaining topics (2-9, 12, and
14) that was not provided by the other deponents or Apple’s responses to written discovery. (Joint
Letter at 1.) In opposition, Apple argues that no Rule 30(b)(6) deposition should occur, and that
the noticed topics are not proportional to the needs of the case and/or are unreasonably cumulative
of discovery that Plaintiff has already obtained. (Joint Letter at 2.) During the meet and confer
process, Apple proposed responding in writing to “certain discrete questions” from Plaintiff’s
notice” in lieu of a Rule 30(b)(6) deposition, but Plaintiff rejected that proposal. Id. at 3.
Apple is being unreasonable. As an initial matter, deposing individual fact witnesses is
fundamentally different than deposing a corporate witness under Rule 30(b)(6). In the case of

On April 14, 2026, Judge Chen extended Plaintiff’s deadline to take the deposition of Apple, Inc.’s corporate witness, pursuant to Federal Rule of Civil Procedure 30(b)(6), to May 14, 2026. (Dkt. No. 352 at 4.) Judge Chen ordered the parties to meet and confer regarding the deposition topics, and ordered them to file a joint discovery letter before the undersigned should they be unable to reach an agreement. Id. at 4-5. During the parties’ meet and confer efforts, Plaintiff agreed to narrow the topics from 14 to 10. (Joint Letter, Dkt. No. 356.) They could not, however, agree on the remaining 10 deposition topics and filed the instant joint discovery letter on April 21, 2026. Id. Plaintiff contends that she seeks information regarding the remaining topics (2-9, 12, and 14) that was not provided by the other deponents or Apple’s responses to written discovery. (Joint Letter at 1.) In opposition, Apple argues that no Rule 30(b)(6) deposition should occur, and that the noticed topics are not proportional to the needs of the case and/or are unreasonably cumulative of discovery that Plaintiff has already obtained. (Joint Letter at 2.) During the meet and confer process, Apple proposed responding in writing to “certain discrete questions” from Plaintiff’s notice” in lieu of a Rule 30(b)(6) deposition, but Plaintiff rejected that proposal. Id. at 3. Apple is being unreasonable. As an initial matter, deposing individual fact witnesses is fundamentally different than deposing a corporate witness under Rule 30(b)(6). In the case of

Rule 30(b)(6) designees, the corporation is responsible for preparing the corporate witnesses and
the testimony binds the entity they are representing. Louisiana Pac. Corp. v. Money Mkt. 1
Institutional Inv. Dealer, 285 F.R.D. 481, 486-87 (N.D. Cal. 2012); see also Storms v. Paychex,
Inc., No. LACV2101534JAKJEMX, 2023 WL 4291436, at *8 (C.D. Cal. May 24, 2023) For that
reason, courts in this district have generally required the production of a corporate witness in this
circumstance, because, “[e]ven if the general topics to be addressed at the 30(b)(6) deposition will
overlap to some extent, the questions asked and the answers given might not.” Mitchell Eng'g v.
City & Cnty. of San Francisco, No. C 08-04022 SI, 2010 WL 455290, at *1 (N.D. Cal. Feb. 2,
2010). Thus, Apple’s argument that Plaintiff has already deposed individual employees rendering
the Rule 30(b)(6) deposition “unreasonably cumulative” is unavailing.
Moreover, to the extent that Apple is asserting privilege on multiple topics, whether the
privilege exists depends on the questions asked. Apple does not know what questions will be
asked, and surely some questions will not be privileged. Nothing is stopping Apple from raising
privilege objections during the deposition in real-time. Furthermore, despite Apple’s protestations
to the contrary, it is not Plaintiff’s responsibility to identify what nonprivileged information she is
seeking beyond the noticed topics before this deposition can go forward. (See Joint Letter at 3.)
Finally, as a practical matter, answering 10 written questions is an inadequate substitute for
a Rule 30(b)(6) deposition, and Apple should know better.
Accordingly, the Court orders that the Rule 30(b)(6) deposition go forward. The only topic
that the Court finds irrelevant to the remaining claims is Topic 12, which seeks information
pertaining to post-termination social media communications and monitoring. All other topics (2-9,
and 14) pertain to pre-termination issues or the terminat…

Rule 30(b)(6) designees, the corporation is responsible for preparing the corporate witnesses and the testimony binds the entity they are representing. Louisiana Pac. Corp. v. Money Mkt. 1 Institutional Inv. Dealer, 285 F.R.D. 481, 486-87 (N.D. Cal. 2012); see also Storms v. Paychex, Inc., No. LACV2101534JAKJEMX, 2023 WL 4291436, at *8 (C.D. Cal. May 24, 2023) For that reason, courts in this district have generally required the production of a corporate witness in this circumstance, because, “[e]ven if the general topics to be addressed at the 30(b)(6) deposition will overlap to some extent, the questions asked and the answers given might not.” Mitchell Eng'g v. City & Cnty. of San Francisco, No. C 08-04022 SI, 2010 WL 455290, at *1 (N.D. Cal. Feb. 2, 2010). Thus, Apple’s argument that Plaintiff has already deposed individual employees rendering the Rule 30(b)(6) deposition “unreasonably cumulative” is unavailing. Moreover, to the extent that Apple is asserting privilege on multiple topics, whether the privilege exists depends on the questions asked. Apple does not know what questions will be asked, and surely some questions will not be privileged. Nothing is stopping Apple from raising privilege objections during the deposition in real-time. Furthermore, despite Apple’s protestations to the contrary, it is not Plaintiff’s responsibility to identify what nonprivileged information she is seeking beyond the noticed topics before this deposition can go forward. (See Joint Letter at 3.) Finally, as a practical matter, answering 10 written questions is an inadequate substitute for a Rule 30(b)(6) deposition, and Apple should know better. Accordingly, the Court orders that the Rule 30(b)(6) deposition go forward. The only topic that the Court finds irrelevant to the remaining claims is Topic 12, which seeks information pertaining to post-termination social media communications and monitoring. All other topics (2-9, and 14) pertain to pre-termination issues or the terminat…

Apple's still hiding lots of info about my suspension & termination, & refused to let me depose Apple Inc as the corp (Rule 30B6 depo). I had to raise it to both federal Judges in my case & both ordered Apple to sit fr my depo, & today the discovery Judge even said Apple was being unreasonable. ⚖️🫡

1 hour ago 1 1 1 0
hand approaching macbook pro with a usb A flash drive. The macbook only has USB C ports. Text: Fig. A: User protected from threat

hand approaching macbook pro with a usb A flash drive. The macbook only has USB C ports. Text: Fig. A: User protected from threat

Practical information security

1 hour ago 94 23 2 2

the “shoplifting is good” opinion piece in the new york times is the purest form of bait, and there is no need to engage with it

1 hour ago 71 11 4 1
Flat, illustrated poster graphic of a Florida Scrub-Jay in flight titled "I'm worth more than 100 tech bros!"

Flat, illustrated poster graphic of a Florida Scrub-Jay in flight titled "I'm worth more than 100 tech bros!"

1 hour ago 944 284 3 2

For those who don't know what radiation therapy is & how crucial it is for a cancer patient to be consistent: it has the same function as chemotherapy. It reduces the growth rate of the cancer cells & quite literally is what's keeping Rebeka alive rn.

CHIP IN $1 to keep Rebeka alive please‼️

15 hours ago 28 37 0 1

Congress can (legally) remove Trump.

It takes 50%+1 of the House & 2/3 of the Senate and we are not starting from zero.

We must compel & pressure our congressional delegations as part of our diversity of tactics.

Trump et al must be removed from power ASAP.

4 hours ago 130 61 8 3
Preview
a man says we have to stop this in front of a paramount sign Alt: a clean shaven white man mostly balding with short brown hair wearing a tan jacket & black shirt has his head tilted and is saying emphatically “we have to stop this”

5/5

Trump’s nuclear launch authority and his unconstitutionally broad command of USA military forces are Bad for a large variety of reasons, some of which are all too obvious in this very moment.

We are in mortal danger so long as we leave him & the Regime in power.

2 hours ago 11 2 1 0

6/5

And the nuclear launch authority and military command are things we’ll have to address in the coming reconstruction.

2 hours ago 10 1 0 0
interior shot of a Twingo driving across the Golden Gate Bridge

interior shot of a Twingo driving across the Golden Gate Bridge

Twingo motion-blurred silhouette against a hillside

Twingo motion-blurred silhouette against a hillside

Twingo at a Sinclair station

Twingo at a Sinclair station

Twingo among redwoods

Twingo among redwoods

twingos came up on the bonus episode so I was just thinking back to one of the coolest road trips of my life with @rustyspeednut.roadsoda.fun in his

2 hours ago 136 15 14 0

Despite what the legislator is claiming, this isn't theoretical. Louisiana cops cited this woman for "indecent" exposure for wearing a crop top.

Even with a dismissal, that's legal fees, sleepless nights and public shame.

Harassment is meant to send a message.

3 hours ago 161 72 4 1
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some good news: H.R. 1897, the awful bill attacking the Endangered Species Act, has been pulled from a vote and FAILED

3 hours ago 431 119 8 10

Still needed & she needs funds for sanitary supplies
linktr.ee/vickivvinters

21 hours ago 14 20 0 1
A warning box stating "The group or resource is not in the correct state to perform the requested operation."

A warning box stating "The group or resource is not in the correct state to perform the requested operation."

same

3 hours ago 12 1 0 0

if you have spare money to help kia with rent and other essentials, see her pinned post

3 hours ago 2 2 0 0

"Red states" don't exist.

Politically disenfranchised and voter suppressed states exist.

It is not coincidental that these states have enormous Black, Latino, and impoverished populations.

And yes, this does make it racist to argue that "red states deserve what they get".

4 hours ago 53 25 1 0

a means to propagate supremacist culture

3 hours ago 5 3 0 0

if you have spare money to help a food-insecure indigenous family avoid getting hit by very high interest rates from maxing out credit in an emergency, chip in here

3 days ago 3 3 0 0

lettuce be the judge of that

6 hours ago 5 0 0 0

Have noticed over the years that some artists post soft-thirst-trap artistic erotic or semi-nude images of themselves on their social media as a marketing technique in addition to their art to increase engagement and sales of their work and I think I might be doing it wrong

6 hours ago 111 7 13 0
painting of the seabed with fish and a crab

painting of the seabed with fish and a crab

sea 02

6 hours ago 81 17 1 0
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interesting!

8 hours ago 1 0 0 0
A digital illustration in simple outlines and flat textured color. A man with a white mustache wearing a sun hat is pushing an ice cream cart with bells hanging from the handle.  Along with pictures of popsicles, text on the side and front of the cart reads ‘Maybe it’ll happen today’

A digital illustration in simple outlines and flat textured color. A man with a white mustache wearing a sun hat is pushing an ice cream cart with bells hanging from the handle. Along with pictures of popsicles, text on the side and front of the cart reads ‘Maybe it’ll happen today’

9 hours ago 607 166 2 3

this indigenous family has been going hungry for months and recently took on expensive debt to cover an emergency, they need about $500 to avoid predation by the bank

please chip in if you can

2 days ago 2 8 0 0