This also "drags back in" the breaches of employment terms Elon Musk allegedly committed when he fired all those X-itter workers two years ago (as he bought it, and rebranded Twitter as. . . X-itter). Obviously, he's using the exact same playbook here, is the allegation (see the last several pages of this attachment -- at pages 10, 11 and 12 -- to the discovery motion).
. . .All documents, including responses, produced in response to Plaintiff States’ First Set of Written Discovery in New Mexico v. Musk, No. 1:25-cv-429 (D.D.C. filed February 13, 2025), and the consolidated case Japanese American Citizens League v. Musk, 1:25-cv-643 (D.D.C. filed Mar. 5, 2025), including copies of Defendants’ answers to all requests for production, interrogatories, and requests for admission, including objections, as well as any exhibits, attachments, logs, files, or other things produced in response to Plaintiff States’ requests in that case, as well as any deposition transcripts produced. . . .
Plaintiff also seeks a deposition of DOGE under Fed. R. Civ. P. 30(b)(6) on the following topics:
. . .Describe all instances in which any DOGE employee told an employee of a federal agency that the DOGE employee would or could call law enforcement in response to the other employee’s conduct, including who made such statement, the federal agency and conduct of the federal agency employee at issue, the law enforcement entity referenced, and, if the law enforcement was called, who made the call and law enforcement’s response. . . .
Identify whether any DOGE employee or DOGE Team member has used or presently uses non-official messaging systems or applications with auto-delete functionality, including but not limited to Signal, to conduct government business [in violation of federal record-keeping laws; and identify. . .]
DOGE’s establishment, mission, responsibilities, personnel, leadership structure, authorities, and decision-making and reporting structure (including the relationship of DOGE to DOGE Teams and DOGE employees detailed to or otherwise working at or with federal agencies and the relationship of DOGE Teams to federal agencies) between January 20, 2025 and the date of deposition.
The scope of DOGE’s and DOGE Teams’ authority with regard to federal agencies, and actions DOGE or DOGE Teams have actually undertaken with regard to federal agencies, between January 20, 2025 and the date of deposition.
The role and responsibilities of all DOGE employees detailed to or otherwise working at or with federal agencies, or having supervisory authority over DOGE employees detailed to or otherwise working at or with federal agencies, between January 20, 2025 and the date of deposition, including their titles at DOGE and any federal government entity; their responsibilities at federal agencies, DOGE, and any other federal government entities to which they have been detailed and/or otherwise assigned; their authority with regard to other federal agency staff; the supervision of said DOGE employees; and the policies, procedures, and protocols pertaining to their detailing to and activities at other federal agencies.
DOGE’s budget, resources, funding, and expenditure of federal funds.
DOGE’s recordkeeping and retention policies and practices. . . .
Yep -- these jamokes are in for a rough ride. Just as it ought to be. Onward.
नमस्ते
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