Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 1 of 12
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`(Additional counsel on following page)
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`ASHLEY M. GJOVIK
`2108 N. St. Ste 4553
`Sacramento, CA 95816
`(408) 883-4428
`legal@ashleygjovik.com
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`Pro Se Plaintiff
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`JESSICA R. PERRY (SBN 209321)
`jperry@orrick.com
`MELINDA S. RIECHERT (SBN 65504)
`mriechert@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Telephone:
`+1 650 614 7400
`Facsimile:
`+1 650 614 7401
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`KATHRYN G. MANTOAN (SBN 239649)
`kmantoan@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`The Orrick Building
`405 Howard Street
`San Francisco, CA 94105-2669
`Telephone:
`+1 415 773 5700
`Facsimile:
`+1 415 773 5759
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`Attorneys for Defendant
`Apple Inc.
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN FRANCISCO DIVISION
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`ASHLEY GJOVIK,
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`Case No. 23-cv-4597-EMC
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`v.
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`APPLE INC.,
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`Plaintiff,
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`Defendant.
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`4126-4871-2528
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`JOINT CASE MANAGEMENT
`STATEMENT
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`Courtroom 5, 17th Floor
`Dept:
`Honorable Edward M. Chen
`Judge:
`Date: July 16, 2024
`Time: 1:30 p.m.
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 2 of 12
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`KATE E. JUVINALL (SBN 315659)
`kjuvinall@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`631 Wilshire Blvd., Suite 2-C
`Santa Monica, CA 90401
`Telephone:
`+1 310 633 2800
`Facsimile:
`+1 310 633 2849
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`RYAN D. BOOMS (SBN 329430)
`rbooms@orrick.com
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`2100 Pennsylvania Avenue NW
`Washington, D.C. 20037
`Telephone:
`+1 202 339 8400
`Facsimile:
`+1 202 339 8500
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`Attorneys for Defendant
`Apple Inc.
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`4126-4871-2528
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`

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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 3 of 12
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`Plaintiff Ashley Gjovik (“Plaintiff”) and Defendant Apple Inc. (“Defendant” or “Apple,”
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`and collectively with Plaintiff, the “Parties”) hereby jointly submit this Joint Case Management
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`Statement in advance of the July 16, 2024 Case Management Conference.
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`I.
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`JURISDICTION AND SERVICE
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`This Court has diversity jurisdiction pursuant to 28 U.S.C. § 1332 because the amount in
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`controversy exceeds $75,000 and the Parties are diverse. Defendant has been served.
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`II.
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`FACTS
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`Plaintiff’s Position: Apple Inc. intentionally engaged in a course of unlawful conduct and
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`unfair business practices that resulted in direct, severe, and ongoing harm to Ashley Gjovik as a
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`neighbor and community member, as an employee, and as a consumer. This lawsuit arises from
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`Apple’s reckless disregard of environmental regulations and safety requirements around two Santa
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`Clara County properties starting in 2015. Apple's acts and omissions resulted in severe and nearly
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`fatal physical injuries to Gjovik in 2020, creating continued and present suffering.
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`Gjovik's complaints and inquiries to Apple about toxic waste in 2021 were swiftly met with
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`retaliation and intimidation, including the adverse employment actions of unfavorable
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`reassignment, interrogations, surveillance, five weeks of mandatory administrative leave, sabotage,
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`denial of benefits and opportunities, suspension, wrongful termination, disparagement, defamation
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`by reason of termination, denylisting, and more harassment. In the years that followed, Defendant
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`engaged in extensive surveillance of Plaintiff and trespass of her property, including repeated
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`burglaries and stalking. Defendant continues to terrorize Plaintiff ongoing, destroyed her reputation
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`and employability, erased her life savings, and has generally made her life utterly miserable.
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`Defendant’s Position: Plaintiff worked for Defendant from February 2015 until Defendant
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`terminated her employment in September 2021 because she disclosed confidential product-related
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`information in breach of her confidentiality obligations and then refused to meaningfully participate
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`in the internal investigation regarding that disclosure. In January 2015, Plaintiff signed a
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`confidentiality agreement “prohibit[ing] [Plaintiff], during or after employment, from using or
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`disclosing, or permitting any other person or entity to use or disclose, any Proprietary Information
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`without the written consent of Apple[.]” Further, in July 2018, Plaintiff voluntarily agreed to
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`4126-4871-2528
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 4 of 12
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`participate in a confidential user study of an internal and proprietary application (the “Application”)
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`and agreed, as a condition of participating, to maintain strict confidentiality. The consent form
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`permitted Plaintiff to withdraw from the study at any time. On August 28, 2021, Plaintiff publicly
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`disclosed on Twitter (now known as X) details about a proprietary study Defendant was conducting
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`about a confidential Apple product (the “Product”) that Plaintiff had agreed to keep confidential.
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`Despite this, Plaintiff’s tweet both identified the name and purpose of the study regarding the
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`Product. On August 30, 2021, Plaintiff tweeted photographs and a video of herself created by the
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`Application, thus disclosing Apple confidential information. She also linked to a story published in
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`The Verge, a technology blog, in which she disclosed her participation in the study regarding the
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`Application. Upon learning of her unauthorized disclosures, Defendant began an investigation. On
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`September 9, 2021, an Apple investigator requested to speak with Plaintiff as part of that
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`investigation. Plaintiff refused to be interviewed. Defendant completed its investigation, concluded
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`that Plaintiff had violated her confidentiality agreements and Apple policy, and terminated her
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`employment. Apple had likewise terminated the employment of other employees found to have
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`violated their confidentiality obligations. In addition to her employment claims, Plaintiff asserts
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`various torts against Defendant. Defendant denies any wrongdoing.
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`III. LEGAL ISSUES
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`Plaintiff’s Position: Legal issues include causation, nexus, intent, negligence, pretext, fraud,
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`protected activities, fairness, and risk. There will be multiple “Reasonable Person” exercises
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`including foreseeability, expectation, severity, outrage, consent, offensiveness, endurance, and
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`interference. The "Right to Know" will be a recurring theme. This case also involves several novel
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`legal issues requiring policy arguments and creative advocacy from both parties related to privacy,
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`surveillance, ears, expression, hazards, consent in the employment context, and personal data
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`collection for commercial research and development.
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`Defendant’s Position: It is too early to determine the legal issues until after the pleadings
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`have been determined but they likely include: Whether Plaintiff engaged in protected activity under
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`Cal. Labor Code §§ 98.6, 232, 232.5, and/or 6310 and/or Tameny, and, if so, whether the protected
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`activity was a substantial motivating reason for Defendant’s decision to terminate Plaintiff’s
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`JOINT CASE MANAGEMENT STATEMENT
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`employment; Whether Defendant is liable to Plaintiff for a private nuisance or breach of contract;
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`Whether Plaintiff is entitled to any relief and if so, the type and/or amount; Whether Plaintiff has
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`adequately mitigated any damages she claims to have incurred.
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`IV. MOTIONS
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`Plaintiff’s Position: At this time Plaintiff has no definite plans to file additional motions but
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`is planning to potentially file a Motion for Summary Judgement on certain Questions of Law after
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`discovery. Plaintiff may also need to file Motions to Compel and other discovery related motions,
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`based on Defendant’s discovery conduct in this case and the U.S. Dept. of Labor case thus far.
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`Defendant’s Position: Defendant intends to file a motion to dismiss on July 15, 2024
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`regarding certain claims in the now-operative Fourth Amended Complaint. Defendant may file a
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`motion for summary judgment under Rule 56 for resolution of any outstanding issues.
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`V.
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`AMENDMENT OF PLEADINGS
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`Plaintiff’s Position: As this is complex litigation covering multiple legal subject areas,
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`Plaintiff expects she will need to amend her complaint again prior to trial to conform with evidence
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`identified during discovery and/or as the issues narrow and crystalize. Plaintiff will also respectfully
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`request leave to amend if any of Defendant’s upcoming 12(b)(6) requests are granted.
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`Defendant’s Position: Plaintiff filed a Fourth Amended Complaint on June 17, 2024;
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`Defendant intends to file a motion to dismiss. Defendant contends that no further amendments
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`should be permitted.
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`VI.
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`EVIDENCE PRESERVATION
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`The Parties have reviewed the Guidelines Relating to the Discovery of Electronically Stored
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`Information and have met and conferred pursuant to Federal Rule of Civil Procedure 26(f)
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`regarding reasonable and proportionate steps taken to preserve evidence relevant to the issues
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`reasonably evident in this action
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`VII. DISCLOSURES
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`Plaintiff’s Position: Plaintiff will provide initial disclosures to Defendant on July 9 2024, as
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`required by Rule 26(a)(1) following their meet/confer, and expects Defendant to do the same.
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`Defendant’s Position: Defendant timely and fully complied with the initial disclosure
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`JOINT CASE MANAGEMENT STATEMENT
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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 6 of 12
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`requirements of General Order 71 (“GO 71”). Plaintiff has not fully complied with GO 71’s
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`requirements.
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`VIII. DISCOVERY
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`• Discovery taken to date:
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`Plaintiff’s Position: Discovery began in the U.S. Dept. of Labor case in March 2024. However,
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`Plaintiff had to file a Motion to Compel two weeks ago. It is Plaintiff’s understanding that discovery
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`did not start in this civil case until the completion of the 26(f) conference in June 25 2024. Plaintiff
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`believes discovery has now started and she may send Defendant her first Request for Production.
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`Defendant’s Position: None.
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`• Scope of anticipated discovery:
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`Plaintiff’s Position: Plaintiff believes the scope should be nonprivileged matters that are
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`relevant to any party's claim or defense.
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`Defendant’s Position: Discovery should be stayed until the pleadings are settled because,
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`until then, the appropriate scope of discovery is unknown (i.e., neither the Parties nor the Court can
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`fully determine what matters are “relevant to any party’s claim or defense and proportional to the
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`needs of the case” within the meaning of FRCP 26(b)(1)). Alternatively, discovery prior to
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`Defendant’s answer should be limited to written discovery related to the claims not at issue in
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`Defendant’s forthcoming motion to dismiss.
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`• Proposed limitations or modifications of the discovery rules:
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`Plaintiff’s Position: There will be some overlapping discovery in this case and the U.S. Dept
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`of Labor OALJ case (with active discovery underway). Because of the potential for conflicts -
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`especially decisions related to privilege, confidentiality, and exclusion of evidence - coordination
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`between cases will be urgent and critical to ensuring consistency and progress.
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`Defendant’s Position: Discovery should be limited at this time as outlined above. With this
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`exception, Defendant contends there should be no modifications of the discovery rules.
`• A brief report on whether the parties have considered entering into a stipulated e-
`discovery order:
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`Plaintiff’s Position: Plaintiff is receptive to the idea.
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`Defendant’s Position: Defendant does not believe that a stipulated e-discovery order is
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`JOINT CASE MANAGEMENT STATEMENT
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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 7 of 12
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`necessary or appropriate in this action.
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`• Proposed discovery plan pursuant to Fed. R. Civ. P. 26(f):
`o (A) what changes should be made in the timing, form, or requirement for
`disclosures under Rule 26(a), including a statement of when initial disclosures
`were made or will be made;
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`Plaintiff’s Position: Initial Disclosures are to be made on Tuesday July 9 2024 in compliance
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`with Rule 26(a)(1), following the party’s June 25 2024 meet and confer. Defendant has not
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`completed its disclosures for any of the claims, but especially for the Toxic Torts, IIED, and antitrust
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`claims – which have no relation to General Order 71, and their applicability in this case is exactly
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`why General Order 71 does not and should not apply. Defendant needs to provide full disclosures.
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`Defendant’s Position: Defendant does not propose any changes to the timing, form, or
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`requirement for disclosures under GO 71. Defendant made its initial GO 71 disclosures on
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`December 18, 2023 and supplemented them on April 5, 2024 and May 15, 2024. Plaintiff has not
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`fully complied with GO 71’s initial disclosure requirements.
`o (B) the subjects on which discovery may be needed, when discovery should be
`completed, and whether discovery should be conducted in phases or be limited
`to or focused on particular issues;
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`Plaintiff’s Position: Discovery should commence. Plaintiff recommends phases, starting
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`with targeted questions that will help narrow the focus of subsequent phases. Plaintiff has also
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`already offered numerous compromises and accommodations to Defendant, including redactions
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`and physically viewing sensitive documents at an office for a more focused selection of which
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`documents are needed prior to taking possession. Plaintiff requests guidance of the procedure for
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`quantity of interrogatories for a lawsuit such as this that is essentially a proactive Rule 18 Joinder
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`of separate claims. Plaintiff has limited resources and will be unable to afford many depositions,
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`but would like to supplement with interrogatories and would benefit from her interrogatory quantity
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`being allotted for at least the whistleblower/labor and toxic tort causes separately (so double).
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`Defendant’s Position: Discovery should be stayed until the pleadings are settled.
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`Alternatively, discovery should be limited to written discovery related to the claims not at issue in
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`Defendant’s forthcoming motion to dismiss. At this time, it is premature to set a date for the
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`completion of discovery.
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 8 of 12
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`o (C) any issues about disclosure, discovery, or preservation of electronically
`stored information, including the form or forms in which it should be
`produced;
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`Plaintiff’s Position: There are already multiple issues related to discovery, including refusal
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`to provide FRCP Initial Disclosures, reliance on boilerplate objections, refusal to provide privilege
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`logs, claims of ACP in conversations where no attorney was present, and insistence on use of
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`blanket protective orders to claim confidentiality of matters that are not confidential (and even on
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`matters that are clearly of the public interest and/or matters of public safety).
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`Defendant’s Position: None at this time, other than whether Plaintiff is required to comply
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`with GO 71, and whether discovery should be stayed until after the pleadings are settled.
`o (D) any issues about claims of privilege or of protection as trial-preparation
`materials, including—if the parties agree on a procedure to assert these claims
`after production—whether to ask the court to include their agreement in an
`order under Federal Rule of Evidence 502;
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`Plaintiff’s Position: Concerns about Defendant’s willingness to provide privilege logs.
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`Defendant’s Position: None at this time.
`o (E) what changes should be made in the limitations on discovery imposed under
`these rules or by local rule, and what other limitations should be imposed;
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`Plaintiff’s Position: Plaintiff requests scrutiny of any requests from Defendant for approval
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`of easily abused tools and tactics, such as a blanket protective orders, or frequent vague requests to
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`stay discovery. Plaintiff also requests Defendant be required to ‘show their work’ for any of these
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`types of requests, and provide a full, proper justification for each issue and request. Plaintiff
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`requests high scrutiny of any requests from Defendant to this Court that appear to be an attempt to
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`censor and silence her – especially about topics like public safety. Plaintiff accepts all responsibility
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`for her conduct and any sanctions if she does actually act improperly.
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`Defendant’s Position: Discovery should be limited at this time as outlined above.
`o (F) any other orders that the court should issue under Rule 26(c) or under Rule
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`Plaintiff’s Position: Structure would be helpful around depositions, interrogatories,
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`document production, privilege, expert witnesses, discovery disputes, and ADR.
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`Defendant’s Position: Defendant proposes no such orders at this time.
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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 9 of 12
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`• Identified discovery disputes:
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`Plaintiff’s Position: There are multiple disputes related to scope, process, confidentiality, and
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`willingness to participate in discovery. Further, Plaintiff continues to allege, (and her NLRB claim
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`is still pending a decision), that Defendant’s actions in December 2023 under the premise of
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`General Order 71 and a Protective Order (where Defendant claimed Plaintiff’s performance
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`reviews, health benefits, and EHS complaints were secret and confidential) violated federal law.
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`Defendant’s Position: Plaintiff has not fully complied with the initial disclosure
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`requirements of GO 71 and should promptly complete her initial disclosures.
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`IX. RELATED CASES
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`Plaintiff’s Position: There are no other pending actions in federal or state Courts. There is
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`one pending agency adjudication within the U.S. Dept of Labor Office of Administrative Law
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`Judges in Boston, MA (Ashley Gjovik v Apple Inc, Case No. 2024-CER-00001). Coordination of
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`cases is required as there are overlapping claims and damages, and Defendant has already taken
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`several actions to initiate conflicts between and within the two cases. Plaintiff would appreciate
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`guidance if a Notice of Pendency is appropriate for this type of adjudication, and/or how to request
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`assistance with or guidance on the preferred way to coordinate cases with this Court and the OALJ
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`ALJ. Plaintiff also has multiple charges filed against Defendant with the US NLRB, and the US
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`NLRB has already found merit that there is substantial evidence the Defendant may have violated
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`the NLRA under two of her claims, however any litigation would not include Plaintiff as a party.
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`Defendant’s Position: On August 26, 2021, Plaintiff filed a charge against Defendant before
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`the National Labor Relations Board alleging that Defendant retaliated against her because she
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`engaged in protected concerted activity. No decision has been issued. On December 29, 2023,
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`Plaintiff filed another NLRB charge against Defendant alleging that Defendant is forbidding her
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`from talking about this case by requesting that she enter into a protective order regarding discovery
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`(modeled on the N.D. Cal. template). No decision has been issued.
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`On August 29, 2021 and November 2, 2021, Plaintiff filed whistleblower retaliation
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`complaints with the U.S. Department of Labor (DOL) alleging that her suspension and termination
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`amounted to retaliation in violation of the Sarbanes-Oxley Act (SOX), the Occupational Safety and
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`Health Act (OSHA 11(c)), and the Comprehensive Environmental Response, Compensation and
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`Liability Act (CERCLA). With respect to her SOX claim, this Court dismissed it with prejudice on
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`May 20, 2024. With respect to her CERCLA and OSHA 11(c) claims, DOL found no reasonable
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`cause on December 8, 2023. On January 7, 2024, Plaintiff requested a hearing before the Office of
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`Administrative Law Judges regarding her CERCLA claim. The hearing is set for the week of March
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`3, 2025. On April 29, 2024, the Secretary of Labor concluded on administrative review that there
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`was insufficient evidence to establish any violation of OSHA 11(c); this is a final DOL decision.
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`X.
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`RELIEF
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`Plaintiff’s Position: Plaintiff requests damages (compensatory, expectancy, consequential,
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`punitive, nominal, restitution, tax offsets, interest, pro se attorney's fees, and legal costs), as well as
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`injunctive and declaratory relief. Estimates for non-pecuniary, punitive, toxic, and other complex
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`matters will be determined later in the lawsuit or by a jury. In 2020, Plaintiff's total annual pay
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`without benefits was $386,382. Employment-related damages are estimated at around $10M for
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`combined back pay, front pay, loss of future earnings, costs, personal injury, and loss of benefits.
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`A non-pecuniary injury multiplier of 4 x pecuniary is suggested, raising the total to $31M. An
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`additional $2M is estimated for interest, tax offset, and attorney’s fees. Post-employment IIED
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`damages would be separate. Toxic Tort compensatory damages will be based on physical and
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`mental injury, diminished value and lost use of chattel and real property interests, and expenses. A
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`non-pecuniary injury multiplier of x5 is suggested (risk of disease, fear of cancer, emotional
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`distress, diminution of quality of life, pain and suffering, and loss of enjoyment of life). The total
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`amount is expected to be similar or more than the whistleblower and labor damages. Plaintiff will
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`need to develop a plan to avoid damages conflicts and mange preclusion in this concurrent multi-
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`jurisdiction litigation. CACI 3924 “Damages on Multiple Legal Theories” will likely be applicable.
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`Defendant’s Position: Defendant denies that Plaintiff is entitled to any recovery in this case.
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`XI.
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`SETTLEMENT AND ADR
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`Plaintiff’s Position: Parties stipulated to an ADR Settlement Conference. However, Plaintiff
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`is concerned that Defendant will not engage in good faith. Plaintiff asked for confirmation that the
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`Conference scope would be a global settlement of all of Plaintiff's claims against Defendant seeking
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`4126-4871-2528
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`

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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 11 of 12
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`damages (civil, U.S. Dept. of Labor, US NLRB) – as an earnest Settlement Conference requires
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`representation of all cases and law firms (i.e., Morgan Lewis). The Defendant has not responded to
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`this inquiry for over eight months. Plaintiff requests Defendant's candor, and consideration of Early
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`Neutral Evaluation instead if Defendant is not interested in settling at this time or at all.
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`Defendant’s Position: In accordance with ADR Local Rule 3-5, the Parties met and
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`conferred regarding ADR options. The Parties intend to stipulate to an ADR process.
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`XII. OTHER REFERENCES
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`Plaintiff’s Position: Plaintiff does not want arbitration and MDL is not applicable. Plaintiff
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`is interested in the possibility of a special master for discovery disputes.
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`Defendant’s Position: Defendant does not believe that the case is suitable for reference to
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`binding arbitration, a special master, or the Judicial Panel on Multidistrict Litigation.
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`XIII. NARROWING OF ISSUES
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`Plaintiff’s Position: Plaintiff believes that further narrowing of issues should occur through
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`mechanisms such as discovery, stipulated facts, and summary adjudication. Plaintiff believes
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`another 12(b)(6) motion is unnecessary and will waste the Plaintiff and Court’s time and resources.
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`Plaintiff also regrets dropping her RICO 1962(c), 1962(d), Bane, and Ralph claims as she expected
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`that in voluntarily dropping the claims that Defendant would not file another Motion to Dismiss.
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`Defendant’s Position: On July 15, 2024, Defendant intends to file a motion to dismiss
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`certain claims in the Fourth Amended Complaint. Defendant believes it is premature to expedite
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`the presentation of evidence at trial or to request to bifurcate issues, claims, or defenses.
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`XIV. SCHEDULING
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`Plaintiff’s Position: Plaintiff suggests scheduling the trial around one year out with the
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`Court’s standard scheduling of dependent events prior. As an expert project manager, she feels
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`strongly there should always be a project schedule, even if it might need to be adjusted later.
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`Defendant’s Position: Defendant believes that it is premature to set a case schedule prior to
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`a ruling on Defendant’s forthcoming motion to dismiss.
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`XV. TRIAL
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`Plaintiff’s Position: Plaintiff requests a Jury trial for issues of fact and certain issues of law.
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`4126-4871-2528
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`- 9 -
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`

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`Case 3:23-cv-04597-EMC Document 77 Filed 07/09/24 Page 12 of 12
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`Duration of the Jury trial is unknown due to the complexity of claims, but Plaintiff expects at least
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`one week will be needed. Additional time will also be needed for the expected partial Bench trial
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`with Summary Judgement motions on certain Questions of Law.
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`Defendant’s Position: Plaintiff had made a demand for a jury trial. Defendant anticipates
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`the parties would need five days for trial.
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`XVI. DISCLOSURE OF NON-PARTY INTERESTED ENTITIES OR PERSONS
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`Plaintiff’s Position: Plaintiff has no disclosable non-parties who are interested entities or
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`persons in the outcome of her side of this litigation.
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`Defendant’s Position: Plaintiff filed a Disclosure of Conflicts and Interested Entities or
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`Persons. Dkt. 2. Defendant filed a Certification of Conflicts and Interested Entities informing the
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`Court that there is no conflict of interest (other than the named parties) to report. Dkt. 11.
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`XVII. PROFESSIONAL CONDUCT
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`Defendant’s Position: The attorneys of record for Defendant have reviewed the Guidelines
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`for Professional Conduct for the Northern District of California.
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`XVIII. OTHER MATTERS
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`Plaintiff’s Position: Due to the complexity of the case and the current dynamic between
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`parties, Plaintiff sees benefit in regular reoccurring Status Conferences and Updates with the Court.
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`Plaintiff has already utilized the Court’s Pro Se clinic for procedural guidance and plans to continue
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`utilizing the helpful resources available there.
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`Defendant’s Position: Defendant is not presently aware at this time of any other matters that
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`may facilitate the just, speedy, and inexpensive resolution of this matter.
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`Dated: July 9, 2024
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`Dated: July 9, 2024
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`4126-4871-2528
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`By: /s/ Ashley M. Gjovik
`ASHLEY M. GJOVIK
`Plaintiff
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`By: /s/ Jessica R. Perry
`JESSICA R. PERRY
`Attorneys for Defendant Apple Inc.
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`- 10 -
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`JOINT CASE MANAGEMENT STATEMENT
`CASE NO. 23-CV-4597-EMC
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`