Apple's position on civil discovery was that I needed to sign a broad NDA that covered all my work conditions, & everything Apple did to me, before Apple might maybe loan me some docs

My position on civil discovery is motioning for Judicial Notice of thousands of pages of public records

The Motion was filed Dec 25 2023 and Apple had 14 days to respond (which was January 8 2024), but Apple never responded

The hearing is now set for February 15 2024

https://www.courtlistener.com/docket/67772913/gjovik-v-apple-inc/

I struggled putting this motion together with everything else I had to deal with concurrently, but I got it on the calendar & everything in place

I may receive and do deserve a lecture about being more organized with this specific motion

But if the Judge grants my request, even partially, it will mean those records are now 'on the record' when he considers Apple's next response

Which would be very very helpful to me

@ashleygjovik that would be super :D

@mattsiegel Yes!!

"Plaintiff claims she worked at Superfund site" = "825 Stewart Drive is the TRW Microwave Superfund site, where Apple is a tenant, and the US EPA inspected the site's vapor intrusion controls on August 19 2021"

"Plaintiff claims a building at 3250 Scott Blvd is doing silicon fab" = "the building at 3250 Scott is registered with US EPA for semiconductor fabrication and Apple reported 8 tons of hazardous air emissions in 2020"

& so on 🤘