Schobinger v. Twitter, Inc.
- Vince Chhabria
- 3:23-cv-03007
- U.S. District Court · Northern District of California
- 5
In Schobinger v. Twitter, Judge Ryu denied broader document discovery but allowed a three-hour deposition of Mason Eaves.
Mark Schobinger and Twitter, Inc. (identified in the opinion as X Corp. or “Twitter”); the ruling limits additional document production, requires discussions about a possible stipulation, and permits a three-hour deposition of Mason Eaves.
What happened
In Schobinger v. Twitter, Inc., Mark Schobinger claimed Twitter promised employees part of a 2022 bonus but did not pay it. The court had previously denied class certification because it found Schobinger was not an adequate class representative, while noting that Judge Chhabria had not decided the case’s merits.
Schobinger asked for more documents about management communications and the company’s accounting for the bonus, and he sought to depose Mason Eaves. Twitter opposed the requests, arguing that the document searches were too broad and burdensome and that Eaves’s testimony would duplicate an earlier deposition.
Judge Ryu ruled that Twitter did not have to provide additional documents beyond what it had already agreed to produce. She required the parties to meet and confer about a factual stipulation concerning the bonus accrual, but allowed Schobinger to take Eaves’s deposition for three hours.
The detailed version
- Schobinger v. Twitter, Inc. · No. 3:23-cv-03007
- Vince Chhabria
- Jan. 9, 2025
Background
Mark Schobinger brought class-wide claims alleging that Twitter agreed to pay employees part of a bonus contemplated by the 2022 Performance Bonus Plan and then failed to pay it. On October 16, 2024, Judge Vince Chhabria denied class certification, finding that Schobinger was not an adequate class representative because of weaknesses in his individual claim. The opinion states that Chhabria had not ruled on the merits of the case. The court nevertheless considered his assessment when evaluating whether the requested discovery was proportional to the needs of the case.
Schobinger and Twitter filed a joint discovery letter. Schobinger sought to compel further responses to two requests for production, or RFPs, and sought to depose Mason Eaves, Twitter’s Director of Technical Accounting. Twitter opposed the requests.
RFP 2: Management communications
RFP 2 sought all emails, Slack messages, and other communications among Twitter management personnel about paying employees a 2022 annual bonus. The court found that these communications were arguably relevant because they could provide evidence about whether a contract existed and whether Twitter breached it. But the request was not proportional under Federal Rule of Civil Procedure 26(b)(1), which limits discovery to information that is relevant and appropriately matched to the needs of the case.
The court emphasized the weakness of Schobinger’s individual claims, the broad scope of the request, the lack of a clear definition of the management group, and Schobinger’s failure to propose a narrower compromise during the required discussions between the parties. The court ruled that RFP 2 was not proportional and that Twitter did not need to produce responsive documents beyond what it had already agreed to provide.
RFP 6: Financial records
RFP 6 sought all financial records and other documents concerning Twitter’s accumulation of funds for employee bonuses from January 2022 through June 2023. Twitter had offered to stipulate to facts about the funds accumulated for 2022 bonuses, and it stated that it had already produced documents provided to employees, Compensation Committee minutes, and communications about the accrual.
The court ruled that a further response to RFP 6 was not proportional, again citing the weakness of Schobinger’s remaining individual claims and his refusal to narrow the broad request. The court ordered the parties to promptly meet and confer to reach a stipulation about key facts concerning the accrual of funds for a 2022 bonus.
Deposition of Mason Eaves
Twitter argued that Eaves’s deposition would be cumulative and irrelevant because former Twitter Chief Financial Officer Ned Segal had already been deposed about similar subjects. Schobinger responded that Segal had been terminated before the bonus was due to be paid, while Eaves was still working for Twitter. The court concluded that Eaves could reasonably have different knowledge about the bonus accrual and the decision not to pay the bonus.
The court therefore allowed Schobinger to take a three-hour deposition of Mason Eaves. The order resolved the discovery dispute and did not decide whether Schobinger’s contract claims were legally valid.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.