Apple v. Psystar: Things Just Got Really Interesting
- May 1st, 2009 - 3.37 am UTC
- Apple Legal News, Psystar
- dizzle
On April 29, 2009, Apple filed an Administrative Request for An Order Permitting the Filing Under Seal of Confidential Portions of Letter Brief Dated April 29, 2009 (PDF file linked). Wow, exciting, right? Okay, let me explain exactly what is happening as it is a bit juicy. Remember that I am NOT an attorney, and any thoughts are my own lay-opinion. A legal opinion would have to be obtained from a properly licensed qualified attorney.
Short Recap of Necessary Background History
The last filing in the case was March 4, 2009 when Apple filed its Answer to Psystar’s First Amended Counterclaims. My commentary on that filing can be found here. On the previous day the Court had entered an Order Approving Stipulated Protective Order Subject to Stated Conditions . My commentary on that order can be found here. If you recall, at that time I had concluded:
Reading between the lines: Judge Alsup will NOT look favourably upon any gamesmanship during discovery.
At that point the case entered the “discovery” process during which the parties take depositions, perform inspections, exchange documents (Requests for Production), answer written questions under oath (Interrogatories), obtain documents from non-parties (Subpoenas Duces Tecum), and narrow the issues to be proven at trial (Requests for Admissions). Unlike State Court (at least in Florida where I live, and most likely California as well), discovery is not filed with the Court. The only time any filings regarding discovery will be brought before the Court is when there is a dispute between the parties. The most common filing in this regard would be a Motion to Compel one party to adequately answer certain discovery requests which the other party believes were answered inadequately. The Case Management Scheduling Order in this case was docketed as stating:
CASE MANAGEMENT SCHEDULING ORDER: Discovery due by 6/26/2009. Jury Trial set for 11/9/2009 07:30 AM in Courtroom 9, 19th Floor, San Francisco. Motions due by 8/20/2009. Pretrial Conference set for 10/26/2009 02:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge William Alsup on 11/7/2008. (whasec, COURT STAFF) (Filed on 11/7/2008)
A copy of the complete Scheduling Order may be found here.
So, it is quite expected that things would appear to settle down as far as the Court docket is concerned until the expiration of the discovery deadline of June 26, 2009. After that date the really exciting, potentially dispositive pleadings will be filed. There is nothing like a good Motion for Summary Judgment for a great read. Yes, I am a legal geek.
I hope that made things clear so far.
Federal Rules of Civil Procedure 30(b)(6) Depositions
The Federal Rules deal with the issue of obtaining the deposition of businesses which will bind the business to testimony. Below is the Rule in question:
Rule 30. Deposition by Oral Examination
(a) When a Deposition May Be Taken.
******
(b) Notice of the Deposition; Other Formal Requirements.
****
(6) Notice or Subpoena Directed to an Organization.
In its notice or subpoena, a party may name as the deponent a public or private corporation, a partnership, an association, a governmental agency, or other entity and must describe with reasonable particularity the matters for examination. The named organization must then designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on its behalf; and it may set out the matters on which each person designated will testify. A subpoena must advise a nonparty organization of its duty to make this designation. The persons designated must testify about information known or reasonably available to the organization. This paragraph (6) does not preclude a deposition by any other procedure allowed by these rules.
In plain English, in this case it means, for example, Apple can provide notice that it wishes to take the deposition of a Psystar representative with the most knowledge concerning certain listed areas of inquiry and documents. The organization to be deposed can designate one or more persons to testify on behalf of the organization. With large corporations it is common for several people to be so designated. For example, I work with insurance companies. The person with the most knowledge of underwriting may not be the same person with the most knowledge of the claim in question. A sample of some Rule 30(b)(6) areas of inquiry may be found here. Obviously those questions would not be the ones in this case, but it gives you an idea of how the areas of inquiry are specified so that the other party can make an informed decision who to designate, and it limits the scope of that deposition.
Are you still with me?
Psystar Appears to be Playing Games
With the above information in hand, you are in a better position to understand what yesterday’s filing means. Apple is requesting that the Court accept under seal a letter brief with redacted portions, one un-redacted document (Exhibit C). and three other documents redacted in full (Exhibits A, B, and D). Even though the letter brief is redacted, it is VERY interesting. Here is a link to the PDF file of the letter. I am going to reproduce the un-redacted portions here with asterisks (***) inserted where redaction occurs.
Apple’s Letter to Judge Alsup Dated April 29, 2009
Dear Judge Alsup:
Despite numerous meet and confer sessions, defendant Psystar Corporation (“Psystar”) has failed to provide, either through documents or testimony, clearly relevant financial information. Psystar has produced no monthly profit and loss statement, balance sheets or other financial statements and only a small subset of revenue and cost-related receipts. Moreover, at the 30(b)(6) deposition regarding Psystar’s revenues, profits, asserts and liabilities (including investors, lenders or other sources of financial support), taken on March 20, 2009, Psystar’s CEO and founder Rudy Pedraza, the person designated by Psystar to testify on this topic, would not answer basic questions about Psystar’s financials. *** Mr. Pedraza, who runs this small company, stated approximately 90 times during the deposition that he did not know or recall answers to basic questions about Psystar’s sales, its general costs and profits, its costs and profits by product line, how it determined its prices and profit margins, ***.
***
*** Yet, as of the March 20 deposition, no customer purchase receipts or order documents had been produced by Psystar. Indeed, despite a supplemental production on April 13, 2009, Psystar still has not produced customer purchase receipts/invoices from at least April 2008, when it began selling its computers, to October 2008. Additionally, only a subset of vendor invoices3, from December 2008 to March 2009, were produced (and those just one day before the deposition). Similar documents from April to November 2008 are still missing. Due to these deficiencies in both Psystar’s document production and its 30(b)(6) testimony (along with others described below), Apple submits this letter brief requesting an order compelling Psystar to (1) produce financial documents sufficient to determine Psystar’s revenues, costs, profits, assets and liabilities and (2) to make available a knowledgeable 30(b)(6) designee for another deposition on this topic at Psystar’s expense.
I. Procedural Background
On November 4 and 11, 2008 Apple served its First and Second Requests for Production in which it requested Psystar documents related to sales, revenue, costs, profits, asserts, liabilities and financial projection. (RFP Nos. 25, 31, 33–34, 42, 49 and 58&ndash63, language reproduced in Ex. B.)4. After numerous meet and confer sessions on December 17 and 19, 2008 and February 13 and 20, and March 9, 2009, Psystar stated that it would produce documents responsive to these requests after entry of a protective order.5 On March 16, 2009, Apple again reminded Psystar that it had not produced any financial documents (other than a few purchase records through a payment processor) and demanded production before the upcoming 30(b)(6) deposition. One day before the deposition, Psystar produced only a small subset of the vendor invoices mentioned above. After the deposition, Apple sent another letter identifying the documents Mr. Pedraza had testified were produced or may exist at Psystar. (Ex. D.) One week later, and three weeks after the deposition, Psystar produced purchase receipts from October 2008 through March 2009. No additional relevant documents have been produced even though Psystar has been selling computers since April 2008 and Mr. Pedraza testified that Psystar had not destroyed any documents. (Ex. A at 46:14–16.)
II. Categories of Missing Documents
P&L Statements, Balance Sheets and Other Financial Statements. Psystar should be compelled to produce its financial statements. *** Psystar has not produced that data or any financial statement. Moreover Psystar has not produced information that would allow Apple to conduct its damages analysis ***.
Underlying Documentation to Show Sales, Revenue, Costs, Etc. Psystar should also be compelled to produce underlying documentation that is necessary to create a profit and loss statement or balance sheet. *** Based on third-party productions, it is also evident that Psystar exchanged documents with its payment processors that show Psystar’s sales and returns along with the fees paid to those payment processors. Psystar has not produced documents showing all of its sales and revenues from April 2008 to the present.
Furthermore, Psystar has not produced any summary document sufficient to show its costs from when it first began selling products in April 2008 through the present. Even if Psystar does not have a summary document, it should then produce documentation that would allow Apple to determine Psystar’s costs. Psystar has not produced any documents that show its operating costs or overhead costs, including payroll. It has not even produced all the invoices from its own vendors and consultants.6 Rather, Psystar has produced only a smattering of invoices that cover products purchased from December 2008 through March 2009. *** These documents are important to determine Psystar’s profits and margins and must be produced.
Financial Projections. Apple also requested financial projections for Psystar’s products (RFP No. 25). Psystar has produced one financial projection but has not produced the drafts of that financial projection. (See PSY009277.) Those drafts clearly exist. In fact, Psystar has produced emails sending such drafts *** as attachments to e-mails. Psystar, however, has not produced any attachments to e-mails in this case. Psystar should be required to produce the drafts of financial projections and all attachments to e-mails.
Apple respectfully requests pursuant to Rule 37(c) that Psystar be compelled to produce all documents responsive to the categories described above, to provide another knowledgeable witness to complete the 30(b)(6) deposition, and to pay Apple reasonable expenses, including attorney’s fees caused by Psystar’s inordinate failure to produce and testify.
Editorial Commentary
The reader can examine the footnotes in the linked PDF file of the document as well as the exhibit which sets forth the requests that were propounded to Psystar (Exhibit C). Basically what this boils down to is an alleged willful and knowing failure of Psystar to produce complete financial information. I personally find this very interesting in light of the issue of the still-unidentified ten “John Doe” defendants. Apple may be attempting to obtain that information in this parenthetical statement:
(including investors, lenders or other sources of financial support)
Taking the above-letter as absolutely true and unbiased for the sake of argument; it certainly appears that Psystar has run afoul of good-faith discovery. Federal Court Judges usually have little tolerance for such tactics. If it is indeed true that Rudy Pedraza either would not, or could not, answer financial information 90 times that would be bad for Psystar. If Rudy doesn’t know, who does? Is he protecting someone?
In a bit of trivia, it appears that at least nearly 10,000 documents have either been produced so far or marked by Apple as pertinent to the case. How do I know this? Did you notice the statement referring the Court to “PSY009277.” That is a Bates-stamping convention. The document referred to is number 9277 of a batch identified with the prefix “PSY.” I can’t speak for the legal assistants on this case, but that prefix is how I would usually identify documents produced by the opposing party and not internal documents or documents provided by the client.
What’s Next Regarding This Issue?
Psystar will likely file a response or the Court will request a hearing to sort out this dispute. If things are as they appear, I would not be at all surprised to see Psystar monetarily sanctioned as requested by Apple.
Here is a link to the list of all of the prior commentary articles I have written on this case. However, I would draw the reader’s particular attention to the following:
Apple Petitions Court for Leave to Amend Its Complaint Against Psystar [Updated]
Comments
Spade Aceman 1st May 2009, 19.34 pm
Wow – this would seem to be another strong indicator that Psystar is indeed someone else’s pawn.
A bit surprising though that they’d apparently be so ill-prepared for questions they had to know were coming. Or perhaps they’re just playing for time? (Though it’s difficult to see what they’d gain by that, unless they were having a tricky time falsifying the requested data?)
I realize that Hanlon’s razor could apply here (“never attribute to malice that which can be adequately explained by stupidity”), but this whole Psystar thing has been shady since day one, IMHO, and has only gotten shadier as things have progressed (the mysteriously moving headquarters building, the pricey legal team they can somehow afford). I’m very much looking forward to finding out who the puppeteer is behind Psystar’s dancing act.
Thank you for continuing to “translate” the events of this case for a wider audience – I’m sure I’m not the only person who appreciates it!
dizzle 1st May 2009, 21.04 pm
You are very welcome Spade. When I read the new filing, I was salivating all over it, and then I realized that 99% of the people reading would not know the significance of a 30(b)(6) deposition and how utterly bad it is to produce someone who appears to have a lobotomy at the court reporter’s door. It certainly did raise the red flags to me that there is something going on with the finances that they don’t want to say.
However… with Hanlon’s razor, Rudy Psystar has acted like a loud-mouthed swaggering punk since day one. This could just be part of his MO with nothing further needing to be read into it.
Judges however HATE getting dragged into discovery disputes. There are two very funny Court Orders I should post regarding discovery disputes. One out of Florida, has a Federal Court Judge ordering both parties to meet on the courthouse steps to play a game of rock, paper, scissors to settle their deposition disputes.
http://www.floridabar.org/DIVCOM/JN/jnnews01.nsf/8c9f13012b96736985256aa900624829/d2ecda2dd652f58c8525719a004a6160?OpenDocument
It is more hilarious only because I know Mr. Pettinato.
This one is also classic:
http://maisnon.blogspot.com/2007/05/hon-snark-t-snarkerson.html
Spade Aceman 1st May 2009, 21.47 pm
BWAHAHAHA – a game of rock-paper-scissors, brilliant! And the poem one is great too – definitely cautionary tales for anyone who would dare to repeatedly annoy a judge. Which further makes your point that Judge Alsup will probably not look too favorably upon Psystar playing keep-away with the information they’re being asked to provide.
dizzle 1st May 2009, 22.32 pm
And if you knew Pettinato it is even funnier as he is a very colourful character, zealously pleading his client’s case.
BTW, I don’t know if you noticed, but I just posted another article. Judge Alsup, as usual, is on his game. Pretty much first thing this morning (California time), he set the issue for hearing. Psystar has to respond by Monday, and the hearing is set for Tuesday. Colby Springer (Psystar’s attorney) is very clever. I am sure that the response will definitely stir the pot.
But if Alsup doesn’t buy it, this is potentially a very expensive exposure for Psystar. Some Federal Judges impose substantial sanctions. I have seen sanctions that rise almost up to 100K if the violation was grievous. And I am not certain on this (I would have to research the specifics), but I believe that the client is obligated to pay at least a portion of it, i.e. this isn’t simply exposure to Springer but potential exposure to Pedraza himself.
I am very interested in knowing what his 90 non-answers were. Were they “I don’t know” or was it something he was instructed by his attorney not to answer due to some objection although at least in Florida, all objections in depositions are reserved except for form–let me know if you don’t know what I mean by that. This would be evenmoreso as there is a confidentiality agreement between the parties so there is no risk of letting the genie out of the bottle in a way that is impossible to shove it back in.
I expect that the Judge will rule on the spot. Depending upon his Order, and my wallet, I may get the transcript if it seems like there will be some good nuggets in there.
From what I can tell, I don’t see how they can legitimately object to the subject matter. Apple is claiming specific monetary damages, so the amount that Psystar has made is definitely relevant. Their customer list is relevant as they are further seeking a recall. What I did not reproduce in the article, but is contained in a footnote in the letter brief, Apple called Pedraza’s (possible) bluff by asking Psystar to prove that they legimately bought each and every copy of Leopard. Remember, Apple alleged in its Complaint that they did not.
Now generally, I have been involved in a lot of discovery in Miami in the aftermath of Hurricane Andrew, and it is not unusual for the culture there for small business owners not to keep a lot of records. But we are talking about a company that knew it was going to get sued by Apple. There is no excuse.
Also, it is very significant that Pedraza committed that no records were destroyed so he can’t say, well we don’t have them any more, we only keep them for six months. He would have had to say that to avoid a spoliation defense, but now he can’t say they don’t have them.
The dog ate them won’t work in this circumstance.
Maybe a dingo ate your records.
dndgirl 2nd May 2009, 02.52 am
Hi Diz! Just curious to know how you’re getting the documents. Are you using one of your attorney’s PACER accounts? I wanted to get them too, but my firm wouldn’t like if I did that.
Oh, a bit of trivia. California state courts don’t file discovery either, unless there is some kind of dispute.
BTW, have you been following the RealDVD case? It’s kind of interesting too, even though not directly Apple-related.
Laurie
dizzle 2nd May 2009, 04.18 am
Hey I SMS’d you the other day, did you get it? I am getting the documents through PACER with my employer’s blessing as long as I note the charges and it gets deducted out of my paycheck. If they didn’t I would get my own account.
In Florida State Courts all discovery gets filed (not the actual documents produced, but rogg answers do and the like). But then again in Florida, we have terrible privacy laws and the amount of personal information that is public makes it a happy hunting ground for stalkers.