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Research Question
Second step after determining the topic.
Your research question is the most critical part of your research -- it defines the whole process, it guides your arguments and inquiry, and it provokes the interests of the reviewer. If your question does not work well, no matter how strong the rest of the research, the endeavor is unlikely to be successful.
To write a strong research question you will need time. Step away from your computer; consider what drew you to your topic. What about it animates and matters to you? Listen to yourself and start formulating your question by following your own interests. Remember, you will spend a lot of time researching and writing about the proposed project: if it does not interest you in the beginning, it will certainly become very difficult to write about in the end.
Next, extensively research your topic. What have people said about it? How have they framed their research? What gaps, contradictions, or concerns arise for you as you read, talk to people, and visit places?
After you have done this you can go back to your computer or note pad and start crafting the question itself. When you do, consider that a strong research question should be problematic/evocative, relevant, clear, and researchable.
1- The research question should be problematic and evocative.
Evocative questions are ones that catch the interest of the reviewer and draw her/him into the proposal. Equally important, they easily adhere in the reviewers' memory after reading the proposal. Questions tend to be evocative because of the ways they engage with challenging topics: they pose innovative approaches to the exploration of problems, and because of this the answers found are far from obvious. There is no single way to form a conceptually innovative question. However, some of the following qualities are common to successful proposals.
Make it timely. Evocative and problematic questions are often distilled from very contemporary social or theoretical concerns. For example, questions regarding the energy crisis, international tribunals, nationalism, or the rise of anti-globalization protests are likely to peak the interests of others because they are questions whose relevance will be clearly discernable for reviewer.
Think about this one: Why should we attend to a comparative study between Plato's and Aristotle's attitudes toward women's rights unless we link it to the contemporary debates in the West regarding gender issues?
Frame it as a paradox. Frame your question around a provocative paradox. For example, why have indigenous organizations in Bolivia markedly declined while the number and quantity of funding sources has increased? Or why have violent conflicts over forest resources increased in the last ten years while the very people involved in these conflicts have become less and less dependent on forest resources for their livelihoods? There are many potential answers to these questions, and your research may ultimately challenge your own expected explanation -- but this in itself is a relevant discovery. These types of paradoxes pull the reader into the proposal and set up a situation whereby the research will fill in a provocative piece of the puzzle and make clear a much-needed broader understanding.
Take a distinctive approach. Finally, a question that approaches an old problem in a refreshingly new way, or proposes a surprising angle of analysis on a difficult dilemma, is likely to prove evocative for reviewers. This could involve a new methodology, a new conceptual approach, or the linking of two previously disparate fields of knowledge. These innovative approaches both develop confidence in the intellect of the researcher and hold promise for new understandings and insights to old and difficult questions.
2- The research question should be relevant.
Questions that clearly demonstrate their relevance to society, a social group, or scholarly literature and debates are likely to be given more weight by reviewers. Of course the relevance of a research question, not to mention the question of who finds it relevant, will vary widely according to the funding source. As a general rule, research is more likely to be interesting if it is seen as part of a larger intellectual project or line of inquiry, not just a way for the researcher to get a degree. Below are two common ways to demonstrate this in your proposal.
Fill in the missing piece. If your proposal can lay out a given field or dilemma and then point to a specific portion that is missing in that field or dilemma -- a gap which will be filled by the answer to your research question -- your research is likely to garner a great deal of support. Reviewers will note its importance and recognize its relevance to a larger community of researchers.
Make connections. Even if you are working on a narrow topic or in a specific place, ask questions that help relate the research to broader trends, patterns, and contexts. Doing this will help show how funding a seemingly distinct research project helps fuel larger debates. For example, show how someone working in a small town in Outer Mongolia will help understand the broader process of post-Soviet economic transformations.
3- The research question should be clear.
Clear questions tend to be short, conceptually straightforward, and jargon-free. This does not mean they have to be overly simplistic; but save your theoretical gymnastics and abstract disciplinary language for the analysis. Work to keep your questions as lucid and simple as possible. This may be easier in some cases than in others, but some of the strongest and most theoretically sophisticated proposals we reviewed were framed by some of the simplest, most straightforward research questions. In contrast, the most complicated questions tended to appear in proposals where the researcher seemed more interested in demonstrating his/her theoretical knowledge than in engaging the research itself. Below are simple ways to keep your question clear.
Ground the questions. Keep your questions close to the topic or place you are researching. Questions that are too abstract or obtuse make it difficult for the reader to determine your question's relevance and intent. You must still link your question to a larger context, but ground that connection in temporal and spatial specifics.
Parsimony or Limit variables. If a question is burdened with too many variables or too many clauses it becomes both difficult to read and difficult to research. Here are two contrasting examples from the SSRC web site: a question like "Was the decline of population growth in Brazil the result of government policies?" is much easier to understand than "Was the decline in population growth in Brazil related more to sex education, the distribution of birth control, or resource depletion?" You may talk about all these factors in your proposal, but the first question allows the reader to focus on the central aspect of your research rather than the variables surrounding it.
Think about this one: If a piece or research gives you 180 reasons why a person becomes a terrorist, what is the use of the research? What are the policy recommendations we might have?
However, do not be too parsimonious or you will fall in the trap of reductionism.
4- The research question should be researchable.
Research questions need to be clearly "doable." One of the most common rationales for rejecting proposals is that the question is simply too expansive (or expensive) to be carried out by the applicant. There are many questions that you will need to ask yourself to avoid this pitfall. Above all else, consider your limitations. Many very practical questions need to be considered when choosing your research question. First among them is: How long will the research take to carry out? Next, do you have the appropriate background to carry out the research? Are there ethical constraints? Is the project likely to be approved by your advisor and your university's committee for the protection of human subjects? Can you obtain the cooperation from all the necessary individuals, communities and institutions you need to answer the question you have asked? Are the costs of conducting the research more than you will be likely to raise? If I can't complete this project well, can I break it down and address the most important component?
Practical Advice on how to formulate your research question:
How To Do A Literature Review?
What is a Literature Review?
A literature review is a summary of previous research on a topic. Literature reviews can be either a part of a larger report of a research project, a thesis or a bibliographic essay that is published separately in a scholarly journal. Some questions to think about as you develop your literature review:
1. What is known about the subject?
2. Are there any gaps in the knowledge of the subject?
3. Have areas of further study been identified by other researchers that you may want to consider?
4. Who are the significant research personalities in this area?
5. Is there consensus about the topic?
6. What aspects have generated significant debate on the topic?
7. What methods or problems were identified by others studying in the field and how might they impact your research?
8. What is the most productive methodology for your research based on the literature you have reviewed?
9. What is the current status of research in this area?
10. What sources of information or data were identified that might be useful to you?
If the literature review is part of a Ph.D. dissertation, this review will be comprehensive covering all research on the topic. As part of your research report, you need to cover the major work that has been done on the topic recently, but it is not necessary to try to identify all research on the subject.
What is the purpose of a Literature Review?
The purpose of a literature review is to convey to the reader what knowledge and ideas have been established on a topic and what are the strengths and weaknesses. The literature review allows the reader to be brought up to date regarding the state of research in the field and familiarizes the reader with any contrasting perspectives and viewpoints on the topic. There are good reasons for beginning a literature review before starting a research paper. These reasons include:
1. To see what has and has not been investigated.
2. To develop general explanation for observed variations in a behavior or phenomenon.
3. To identify potential relationships between concepts and to identify researchable hypotheses.
4. To learn how others have defined and measured key concepts.
5. To identify data sources that other researches have used.
6. To develop alternative research projects.
7. To discover how a research project is related to the work of others.
How to do a literature search?
Defining the topic - In order to begin your literature review you must first define your research question. What is the purpose? What does it mean? What are the key words? Are there other words which could be used, such as synonyms, variations in spelling? What do you already know about the topic? What is the scope? Do you need everything ever written in English on this topic, or just the last ten years?
Compiling a list of keywords - Before beginning a search for information, it is important to develop a search strategy that will most effectively locate useful, relevant information. This will often involve breaking down an essay or research question into:
keywords or phrases; entering your search; and evaluating your results to determine whether you need to employ various strategies to broaden, narrow or otherwise modify your research.
Analyzing the topic of an essay question or research topic usually involves making a list of keywords or phrases. You will need to include all the key concepts or ideas contained within the essay or research question. It might be useful to include alternative ways of phrasing and expressing concepts and ideas. Think about both general terms and very specific terms for broadening and narrowing your search. The keyword or phrase is the basic unit of any search. You may find it helpful to consult subject dictionaries and encyclopedias, or a textbook glossary for the common terminology of the subject area. The use of an index and/or thesaurus is also advisable to establish the useful terms.
Identifying Resources - Information is available in a number of formats. It is important for you to understand the significance of various formats so that you know what will best suit your information requirements.
Exercise of Literature Review Using JSTOR:
Let us assume that our research topic is related to exploring what variables account for the differences among US citizens toward abortion.
1- Go to JSTOR (Aladl.net >>> Libraries >>> JSTOR).
2- Go to "Advanced Search"
3- In "Full Text" Fields write: "American Gender vote"
4- Lots of articles, let us narrow them down.... We want only articles, from the fields of Political Science and Sociology.
4- Keep searching until you find this one:
Gender Stereotypes and Vote Choice by Kira Sanbonmatsu, American Journal of Political Science, Vol. 46, No. 1 (Jan., 2002).
5- Let us download it.
6- Let us figure out the research topic, the case studies, the data, the analysis technique and the major results.
The big question: Can we do a paper like this one in our class?
You want to know the answer, scroll down...
Keep scrolling...
Good luck!


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Well, I'd say that, overall, I did fairly well today (technically yesterday but since I haven't gone to sleep yet, still today). I had originally planned to go to my apt's gym, but lately the air conditioner hasn't been working so I decided to go for a walk/jog instead. I went from one end of my complex and back. --- I'd estimate a mile or so. I also managed to track EVERYTHING, I ate today. I was able to stay within my ranges for calories, carbs, and protein, but I went quite a bit over on fat grams. Oh well, maybe tomorrow.
It always seems to happen... I have a day off and I plan to workout/get exercise etc and I wake up with a migraine. I don't have all of the symptoms of a typical migraine.... I don't throw up, I'm not usually sensitive to sound. Mostly light affects me, and moving (makes my pulse pound in my temples) oh and I have slight dizziness. So, while I can listen to loud rock music, I CAN'T work out. Walking hurts, hell, even talking hurts. I just get so discouraged because, when I want to work out, I can't. I'm so sick of these headaches. I'm so mad right now, I want to yank off my head and throw it.

subset: commoncrawl


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Legendary singer Patti LaBelle is the 2015 Breast Reconstruction Awareness Campaign spokesperson. The campaign educates and empowers breast cancer patients who are candidates for breast reconstruction by raising awareness about their options and providing access to care.
Marine Cpl. Tyler Southern lost both his legs and his right arm after an IED exploded in Afghanistan. After years of reconstructive surgery, Tyler remains hopeful and optimistic.
Bibi Aisha's nose and ears were brutally amputated when she was a child in Afghanistan. Learn more about her story & amazing recovery.
Join ESPN anchor Hannah Storm, the Hannah Storm Foundation and The Plastic Surgery Foundation to support Caring for Kids, a program that provides access to quality care, regardless of ability to pay.


text:
Springfield Marine Traveler Boat Chair Package
Sale price: Clearance price: Starting at: Sale starting at: Clearance starting at: Reg. price:
- Classic styling and ergonomically cushioned seating
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B rated seat designed for occupancy only at boat speeds not exceeding five miles per hour.
Need Help? 7 days a week: 7am to 10pm CT or call 1.800.227.7776 anytime


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Allstate Sugar Bowl
Enter for a chance to win a pair of tickets to the sold out 2015 Playoff Semifinal at the Allstate Sugar Bowl to see the Alabama Crimson Tide take on The Ohio State Buckeyes on January 1, 2015 as they play for a spot in the first ever College Football Playoff National Championship Game! More »No Purchase necessary. Deadline for entry 12/26/2014.


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Gold Fields Appoints Senior Executives
JOHANNESBURG, March 18, 2013 /CNW/ - Gold Fields Limited (JSE, NYSE, NASDAQ, Dubai: GFI) is pleased to announce the appointment of three new senior executives to the company's Executive Committee.
Kgabo Moabelo has been promoted to Gold Fields' Managing Executive, South Africa. He was previously the Executive Vice-President for People and Organisational Effectiveness for the Group, including its international operations. His appointment took effect on March 1, 2013.
"Following the unbundling of Sibanye Gold from Gold Fields it had become necessary to review the managing structure for the South Africa Region and the South Deep mine," said Gold Fields CEO Nick Holland. "Kgabo will have full responsibility for South Deep's business and operational performance in addition to dealing with the many outside stakeholders that fall within the ambit of the company's South African operations," Mr Holland added.
South Deep is a crucial pillar in the growth of Gold Fields accounting for a significant portion of the company's Mineral Reserves and future production profile. The mine is expected to achieve its full production rate of 700,000 ounces a year by 2016.Mr Moabelo joined Gold Fields in 2010 from Cisco Systems and has held leadership roles not only in mining but in energy, financial services and information technology. His position as head of HR will be taken by Lee-Ann Samuel , who will become Gold Fields' Senior Vice-President, Human Resources and previously headed the company's Remuneration and Employee Benefits portfolio. Ms Samuel, who joined Gold Fields in 2009, has held a number of managerial positions at large private sector companies and has consulted widely to local and provincial government departments. The third appointment is that of Ernesto Balarezo , who has joined the company as Executive Vice-President for South America, to replace Juan-Luis Kruger. Mr Balarezo, a Peruvian national, joins Gold Fields from Hochschild Mining, a Lima-listed mining company, where he was Vice-President, Operations. He has altogether 21 years of professional experience in the industrial and mining industry. Mr Kruger left Gold Fields to become CEO of a privately-held mining company in Peru. Notes to editors
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Modern Dental USA and Sundance Dental Laboratory Announce the Signing of a Strategic Partnership Agreement
Written by Dentistry Today Tuesday, 10 June 2014 12:28
TROY, Mich., June 10, 2014 /PRNewswire/ -- Mike Girard, CEO/President of Modern Dental USA and Steve Dearien, President/Owner of Sundance Dental Laboratory, Scottsdale AZ announced this week that the two companies have signed a strategic partnership agreement.
Modern Dental USA recently announced the opening of its new headquarter facility in Troy, Michigan. In addition, in April 2014, Modern opened a state-of-the-art, high-tech, 20,000 square foot digital processing center at the same location. Its parent company, Modern Dental Laboratory Ltd., is the largest dental laboratory group in the world, holding a leading market position throughout Europe, Asia and Australia. Sundance Dental Laboratory has a long-standing reputation as one of the leading dental laboratories in Scottsdale, AZ.
"We are very pleased to have Sundance join our group. We will continue to invest heavily in North America to expand our network of local neighborhood dental centers, committed to quality, value, and amazing customer support for dentists and their patients across the USA and Canada. Steve and his team now bring some deep knowledge and experience, especially in the design, consultation, and manufacture of implant prosthetics. Sundance Dental Laboratory is the perfect partner and we are excited to build a new implant center with them," says Mike Girard.
Steve Dearien, President/Owner of Sundance said today …."We couldn't be happier to join the Modern Group. Modern is well known around the world as a quality dental manufacturer. This strategic partnership will enable Sundance to chart a strong course for the future. We have already started the design and planning of the new Modern Sundance Dental Implant Center of Excellence right here in Scottsdale."


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Summary: Practical Business Statistics, Sixth Edition, is a conceptual, realistic, and matter-of-fact approach to managerial statistics that carefully maintains-but does not overemphasize-mathematical correctness. The book offers a deep understanding of how to learn from data and how to deal with uncertainty while promoting the use of practical computer applications. This teaches present and future managers how to use and understand statistics without an overdose of technical ...show more detail, enabling them to better understand the concepts at hand and to interpret results. The text uses excellent examples with real world data relating to the functional areas within Business such as finance, accounting, and marketing. It is well written and designed to help students gain a solid understanding of fundamental statistical principles without bogging them down with excess mathematical details.
-User-friendly, lively writing style.
-Separate writing chapter aids instructors in teaching how to explain
quantitative analysis.
-Over 200 carefully-drawn charts and graphs show how to visualize data.
-Data mining is a theme that appears in many chapters, often featuring
a large database (included on the website) of characteristics of 20,000
potential donors to a worthy cause and the amount actually given in
response to a mailing.
-Many of the examples and problems in the sixth edition have been updated
with more recent data sets, and the ever-changing Internet continues to be
featured as a data source.
-Each chapter begins with an overview, showing why the subject is
important to business, and ends with a comprehensive summary, with
key words, questions, problems, database exercises, projects, and
cases in most chapters.
-All details are technically accurate (Professor Siegel has a PhD in Statistics
from Stanford University and has given presentations on exploratory data ...show less
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Bhoot Returns Trailer
The teaser trailer of 'Bhoot Returns' directed by Ram Gopal Varma. The film marks the comeback of actress Manisha Koirala. The film releases on October 12th 2012.
Watch the Bhoot Returns Trailer below
Movie: Bhoot Returns (2012)
Director: Ram Gopal Varma
Starcast: Manisha Koirala, J D Chakravarthi, Madhu Shalini, Alayana Sharma
Producer: Jitendra Jain
Banner: Eros International, Alumbra Entertainment
Release Date: October 12th 2012
For more details: Bhoot Returns Movie Page
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paranormal activity anybody
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4. A "comedy into horror to a horror into comedy" movie.
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Using a Journal Article as a Professional Development Experience
FoY 2007-2008 Equity
Title: Preservice Teachers Examine Gender Equity in Teaching MathematicsAuthor: Maureen D. NeumannJournal: Teaching Children Mathematics Issue: March 2007, Volume 13, Issue 7, pp. 388-395
Rationale for Use
This article describes a project used with preservice teachers to help them recognize possible inequitable teaching practices. This article provides teachers with strategies for identifying and addressing inequitable aspects of their own teaching practice particularly related to verbal interaction. Further, it provides opportunities to adapt the project to address other aspects of inequitable practice. It is recommended that this professional development experience take place in a multi-day format with time between sessions.
Procedures/Discussion Questions
The purpose of the professional development session is to have teachers examine their own teaching practice in terms of creating conditions of equal participation for all students.
Connections to other NCTM Publications
Your feedback is important! Comments or concerns regarding the content of this page may be sent to email@example.com. Thank you.
About NCTM | Standards & Focal Points | Membership | Conferences | Professional DevelopmentJournals & Books | Research, News & Advocacy | Shop Online | Jobs | Advertise | Site Map
The National Council of Teachers of Mathematics is the public voice of mathematics education, supporting teachers to ensure equitable mathematics learning of the highest quality for all students through vision, leadership, professional development, and research.
Use of this Web site constitutes acceptance of the Terms of Use.
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It's a new day MondayHow is everyone? The weather is so gloomy here.
Find a Conversation
It's a new day MondayHow is everyone? The weather is so gloomy here.
|Mon, 06-24-2013 - 8:03am
How is everyone? The weather is gloomy here. It's been raining so much. The weeds have grown in the water retention area behind my house. It must be 5 foot tall, and I'm sure it's filled with tics and wild animals. Thankfully, I am having lunch with a friend. I really miss this woman who lives in the city that I used to live in, an hour away. Today, I am thankful for those I love that surround me. My husband made the mistake of asking our children where they want to go on vacation. I told him it was a mistake, but he wouldn't listen. I do not feel like getting involved at this point. I don't even think I care at this moment. As a "teacher "told me, "let it happen."I need to meditate on the serenity prayer again. SJ, you're right, and I'm trying to take care of everyone around me, again. Gymrat, you are right too, I guess codependency is like alcoholism. I've slipped back into the abyss."Calgon, take me away." Lots of work today, lunch with a friend, Much-needed martini after dinner tonight, no work out. Tomorrow, I will go to yoga. Also, I have friends coming in from California and Florida in the next 10 days. IAM, "playing it by ear, "as I am unsure as to what everyone's plans are.


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|Family Game Day
Event Type: Family Events
Age Group(s): All Ages
Date: 3/22/2013
Start Time: 1:00 PM
End Time: 4:00 PM
Everyone's invited to stop in and play some games. We'll have a Wii set up, Legos, and plenty of board and card games. Bring a friend or bring the whole family!Library: Benson Branch (402.444.4846)
Location: Meeting Room
Contact: Autumn
Contact Number: 402.444.4846


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Planning Director
- Recruiter
- Red Sofa London
- Location
- City of London
- Salary
- £70000 - £80000 per annum
- Posted
- 01 Feb 2013
- Closes
- 01 Mar 2013
- Ref
- Contact
- Amanda Newall
- Function
- Account / Strategic Planning
- Hours
- Full Time
- Contract Type
- Permanent
Our client is a pioneer across the digital landscape, leading the way for over 10 years with revolutionary digital advertising work. They're currently looking for a crucial hire, it's that of Planning Director. As far as the running of the agency goes, it will be your responsibility to be the glue that holds things together… from the way in which the agency works, their insight, inspiration and keeping a watchful eye on what they deliver.
You must have a fantastic knowledge of all things digital…how to engage consumers and make campaigns reach their full potential utilising all elements of the media available to you. Experience working across web development, e-commerce as well as comms campaigns. Managing and overseeing all client activity, helping creatives push boundaries, but most importantly, not loose sight of the end goal, keeping the agencies integrity and fulfilling briefs to the right specifications. Here is what our clients are looking for;
-A logical thinker with a constructive and considered approach to problem solving
-A bright, creative, strategic thinker. A mentor, a manager, a leader
-Gravitas and charisma with clients, good selling strategies as well as developing them
-Solid Planning background, managing a team, spreading yourself across multiple platforms, not caving under pressure!
-Confidence is essential, your experience should speak for itself, they really need a digital planning mogul!
If you've worked in digital planning for a considerable amount of time at top agency we want to hear from you! This agency could offer you that breath of fresh air you've been missing at your current role. They need you to help turn clients ideas into robust and powerful propositions.
Send in your CV today in order to discuss the role further. We look forward to hearing from you!
More jobs like this
- Senior Management / Board / CEO Retail Account / Strategic Planning Agency jobs in London (Central)
- Senior Management / Board / CEO Retail Account / Strategic Planning Digital Agency jobs in London (Central)
- Senior Management / Board / CEO Retail Account / Strategic Planning Strategy / Innovation / Insight jobs in London (Central)


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The Deal: Twitter Sets Up Revenue Streams Prior to IPO #ftw
NEW YORK ( TheStreet) -- Twitter is trying to assure that it doesn't repeat the mistakes of rival social media company Facebook (FB), which took 15 months to catch up to what proved to be an overinflated float price.
Even as the market -- and its own investors -- clamor for the next "IPO of the year," the micro-blogging platform is lining up mega revenue streams to complement its billion-dollar ad business. This could have Twitter invading the space of live events promoters and app store operators like Apple Inc. and Google Inc., say those familiar with the company's plans.
The company has held off on decision-making regarding its initial public offering, sources said, in part because of the unknown trajectory of public markets for the rest of the year.
Indeed, there's a lot to be concerned about, from the central bank pulling back from asset purchases to a possible strike on Syria, plus the next round of Washington hyperbole concerning the U.S.'s deficit limit.At least one investor, however, believes the time is right. "They could do it very quickly this fall," this shareholder said, adding, "I would go now, rather than in 2014." The shareholder, who put the company's market capitalization at about $12 billion, suggested it would rise, but not past $15 billion, by the time it debuts on public markets. That is a substantial contrast to Facebook, which saw eager institutional investors push an oversubscribed offering into a $100 billion market cap leading up to its IPO. An investor in the company said Twitter could very easily raise a fresh round of capital for a longer stay as a private entity, but that few feel this is the optimal path. The company has ramped up its revenue and is expected to exceed $1 billion in advertising revenue, a source said, but Twitter's true potential may lie in yet-undeveloped verticals. News on Tuesday of the hiring of former Ticketmaster Entertainment CEO Nathan Hubbard signaled Twitter's intent to move from live commentary to live events. Though there are incumbents in the sector -- such as Live Nation Entertainment -- they have little presence on social and mobile platforms.
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Despite several...setbacks this year, Kristen Stewart has been looking pretty darn good lately. She's not only been wearing lots more color (including this great beaded flower dress), but the actress has also been looking positive and smiling a bunch on the red carpet. Stewart has also been donning more scandalous outfits, as evidenced by this undergarment-revealing dress that had fashionistas talking the other day. And now she's whipped out another ensemble that's turning heads; check it out here and let us know if you like it!
This is a totally weird look. And I totally love it. Lace is very in this season, but usually you'll see it on froofy, princess-like dresses, not an outfit that could be found in The Matrix. This is a definite hit in my book, and I hope we continue to see more like it!
Hit or miss, Lovelies?


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Daniel MayoraTampa Bay Rays
Infielder | Ht: | Wt:
|Rays | Desmond Jennings among Tuesday cuts
Tue, 15 Mar 2011 10:42:30 -0700
The Tampa Bay Rays reassigned OF Desmond Jennings, P Chris Archer, SS Tim Beckham, C Robinson Chirinos, P Alex Cobb, P Dane De La Rosa, P Brandon Gomes, P Dirk Hayhurst, OF Leslie Anderson, 3B Russ Canzler, 1B J.J. Furmaniak, 1B Daniel Mayora and C Stephen Vogt Tuesday, March 15, according to the St. Petersburg Times' Marc Topkin.
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|| Source: St. Petersburg Times - Marc Topkin
|Rays | Daniel Mayora signs
Fri, 21 Jan 2011 07:44:09 -0800
The Tampa Bay Rays signed free-agent IF Daniel Mayora (Rockies) to a minor league deal, Baseball America's Matt Eddy reports.
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|| Source: Baseball America - Matt Eddy


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How To End A Sales Call And Leave A Lasting Impression
As a salesperson it is always up to you to take the initiative to end the sales call. But saying goodbye to your conversational partner remains a delicate affair. You never get a second chance to make a last impression. There is a huge difference between closing the sale and closing the sales call. So ask yourself, when is the right time to say goodbye and what's the best way to do it?
First of all I recommend you to stick to one of my guiding principles: the goal of the contact is not the deal or the order, it's the customer. The deal or order is merely an expression of the good relationship and fruitful collaboration between the customer and your company. The main objective is to build a lasting, profitable relationship between both parties. No need to say the first step is to leave a good impression. Here is how to do it, whether you got the order or not (yet).
You got the order
One piece of advice: don't leave right away. I know you have tons of other clients to visit, but courtesy demands that you keep the conversation going for a while. The topic of the conversation is not really important, just make sure there's no awkward silences as these can create tension and distrust.
So what can you do?
First of all thank the customer for the business. When customers buy, their decision is for a major part based on emotions. Right after they want to see this decision justified with logic, so give them a little help. Do this in an easy, relaxed, confident way and seal with a handshake.
Mr. Jameson, you made the right choice. I'm convinced that the lawn mower will be very comfortable and will save you a lot of time.
After you have thanked the customer and confirmed their decision, stay a bit longer. Not to talk business, but to discuss hobbies, interests, sports, current affairs,… whatever. Show some interest and treat the customer as a person, or even a friend, instead of only a client. This will increase mutual respect and appreciation.
You didn't get the order (yet)
If you didn't get the order, make sure at least the following elements are clear to you:
- Which elements of your offering does the customer appreciate most?
- Which elements have already convinced them?
- What keeps them from saying yes to your offer?
The response to this last question will give you the opportunity to identify the main objection and pick up the thread of your argumentation again.
Also try to disarm your conversational partner, as he or she is in a state of tension. Remember that you're currently not on the same wavelength. While you are 100% positive about your offer, the customer's attitude towards your product or service is still rather negative since they're not convinced yet. This negative attitude creates some sort of tension that hinders communication. By 'disarming' the customer, you try to get them out of this tense, negative state of mind so that they are prepared to fully communicate with you again.
The following three techniques can help you to disarm the customer.
1. Neutralize the conversation
By neutralizing the conversation we simply mean you should change the conversation to a neutral topic, preferably one the customer is passionate about e.g. hobby, sports, vacation, family,… This technique takes the conversation away from business and allows the customer to relax. The perfect time to get down to business again!
2. Blame yourself
It's no use trying to force or push things. Instead just blame yourself in a humorous way and never lose your smile. If you get a 'no' from a customer you could, for example, make an apologizing gesture and say "Still I'm convinced, Mr. Daniels, that this offering will open up amazing opportunities to you and your business. I must be a worthless salesperson and have dealt with this completely the wrong way if I didn't manage to convince you of the amazing value of our offering to your company."
3. Do the Columbo
If you don't know Columbo, he's a fictional homicide detective from an old crime fiction TV series of the same name. Not only is he great at asking the right questions to get the suspect talking, he is also famous for getting them off-guard and then coming back with a sentence like "oh, just one more thing". This is a very powerful technique that can get you a lot of valuable information. Key is to make it seem truly spontaneous and unrehearsed. It's just an afterthought really. You finish the conversation, pack your things, talk a bit afterwards and then in the doorway come back to business once more with a final question. Because the conversation is already over, the prospect is relaxed and caught off-guard. Either you will learn valuable information about their objections to buying from you or, who knows, you may even still get the order after reentering the office.
After all, a first impression matters most but a last impression stays forever.
Related posts:


text: The Dekline Keaton has a fresh, clean silhouette making this a perfect shoe for chillin', while being loaded with performance features so you can take off on your board without any issues. The suede or canvas upper provides durability and style, while the full-length polyurethane sole offers comfort for all-day wear. A heavy nylex collar lining offers additional, in-step comfort.


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APEX Express, for November 29, 2007 - 7:00pm
Click to Play:APEX Express - November 29, 2007
Play this clip in your Computer's media player
Play this clip in your Computer's media player
Native Gumanians face military might as they try to re-claim land, language, political power. Plans for starting Pacific Islander Studies at UC Berkeley. Plus, Island music and more during Indigenous Peoples' Month.
More from this show: About the Show | Archives of this Show | Playlists from this Show


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Associated Press
WASHINGTON (AP) -- In a stinging rebuke of the military's efforts to curb sexual assault, members of a Senate panel hammered Defense Department officials on Wednesday for making too little progress in combating the crimes and failing to improve a military justice system that victims described as slow and uncaring.
During a two-part hearing, the panel heard harrowing testimony from several victims, who said military justice is broken and pushed for Congress to take action to stem the rape, sexual assault and sexual harassment that they said are pervasive in all the service branches.
Pentagon officials said they are taking the problem seriously. "Sexual assault in the military is not only an abhorrent crime that does enormous harm to the victim, but it is also a virulent attack on the discipline and good order on which military cohesion depends," said Robert Taylor, the Pentagon's acting general counsel.
"The Air Force has zero tolerance for this offense," added Lt. Gen. Richard Harding, the judge advocate general of the Air Force.
But lawmakers pointed to a decision by Air Force Lt. Gen. Craig Franklin to reverse a guilty verdict in a sexual assault case as evidence of how the military fails the victims who come forward to report the crimes. Under military law, a commander who convenes a court martial is known as the convening authority and has the sole discretion to reduce or set aside guilty verdicts and sentences or to reverse a jury's verdict.
Her voice rising, Sen. Kirsten Gillibrand, D-N.Y., said all the promises of "zero tolerance" from the witnesses amount to nothing if a convening authority is the only individual who can decide whether to overturn a case. Gillibrand is the chairwoman of the Senate Armed Services Personnel Subcommittee.
"I appreciate the work you're doing, but it's not enough," she told the military officers arrayed at a long witness table.
Gillibrand then directed her frustration at Harding, demanding to know whether justice was done when Franklin overturned a military jury's conviction. Harding responded that Franklin reviewed the facts and made an independent decision with integrity. Gillibrand then asked whether justice was erved when the five senior officers who made up the jury rendered a guilty verdict. Harding said he could not say.
"The jury and the convening authority did their duty," he said.
Pointing out that they came to opposite decisions, Gillibrand pressed Harding on whether justice was done.
"I'm not going to conclude that justice was or was not done. All parties did what they were asked to do," he said.
"One of the parties was wrong," Gillibrand told him, adding that the female victim in the case does not believe justice was done.
Rebekah Havrilla, a former Army sergeant, told the panel that she encountered a "broken" military criminal justice system after she was raped by another service member while serving in Afghanistan. Havrilla described suffering from post-traumatic stress disorder and described how her case was eventually closed after senior commanders decided not to pursue charges.
"What we need is a military with a fair and impartial criminal justice system, one that is run by professional and legal experts, not unit commanders," Havrilla said.
BriGette McCoy, a former Army specialist and a Persian Gulf war veteran, said she was raped when she was 18 and at her first duty station. But she did not report it. Three years later, she reported being sexually harassed and asked for an apology and to be removed from working directly with the offender.
"They did remove me from his team and his formal apology consisted of him driving by me on base and saying 'sorry' out of his open car door window," McCoy told the subcommittee.
Defense Secretary Chuck Hagel has ordered a review of Franklin's decision to reverse the sexual assault conviction against Lt. Col. James Wilkerson, a former inspector general at Aviano Air Base in Italy. But Hagel has told members of Congress that neither he nor the Air Force secretary is empowered to overrule Franklin, who is the commander of the 3rd Air Force at Ramstein Air Base in Germany.
The case is generating support for legislation that would prevent commanding officers from overturning rulings made by judges and juries at courts-martial proceedings.
"It appears to me that the Aviano general has really failed," said Sen. Claire McCaskill, D-Mo., referring to Franklin.
"This decision has turned the military on its ear," said McCaskill, who added that Franklin's decision sets the Air Force "all the way back to Tailhook." The 1991 Tailhook scandal rocked the military as Navy pilots were accused of sexually abusing female officers at a Las Vegas convention.


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Lego Batman 2: DC Super Heroes Answers for Nintendo DSHome / Nintendo DS /
Game Questions & Answers (Q&A) service lets you ask questions about video games for game consoles or PC games. So ask your Lego Batman 2: DC Super Heroes question for Nintendo DS and get answers from real gamers or answer questions and share your insights and experience with the rest of the gaming community.
- Developer: TT Games
- Publisher: Warner Bros. Interactive Entertainment
- Genre: Action Adventure Modern
- Release Date: Jun 19, 2012
- ESRB: Everyone 10+
Question & Answers
Electric suit and robin swimming
My son and I keep getting stuck on the level when robin is swimming and batman has his electricity suit, not sure what the level is called, but we get to a point when neither character can do anything and there is a room with a swimming crocodile that we cannot get to. Any hints for this?
Answer from: Mattsal23
If you're talking about Arkham Asylum where you put out the fires and Batman walks over the electrical pipes to get to the second pool, once Robin builds the platforms underwater that float up for Batman to stand on, you have to double jump and hold the A button so that Batman grabs onto the electrical structure, then you have to use the b button and the directional pad to jump over and past the structure. It took me a couple of dozen times to finally make it over without falling back in the water. Very frustrating but once you get past that the rest of the level isn't near as tricky. You will need to use the A button grab function in other other levels as well.
Answer from: Simao
Give control to batman. Move batman to the middle of the pool. Move him to the left and press A when getting close to the edge of the pool so he can jump to the upper floor. Once there go to the electricity arcs and pass thru.
Unanswered Questions
From: Awesome
Posted on: 10-23-2014
From: Jay
Posted on: 07-13-2014
From: Anonymous
Posted on: 06-15-2014
From: Batman fan
Posted on: 04-18-2014
From: jarjar
Posted on: 01-06-2014
From: sugar cube
Posted on: 01-03-2014
Lego Batman 2: DC Super Heroes - Minifigures Trailer
- Aug 21, 2014, Views: 225
Lego Batman 2: DC Super Heroes - Trailer
- Aug 21, 2014, Views: 86
- The Penguins Of Madagascar, (DS)
- The Misshitsukara No Dasshutsu, (DS)
- Keiji J.B. Harold No Jikenbo: Satsujin Club, (DS)
- Maru Goukaku: Shikaku Dasshu! Shakaifukushi Samurai Shiken, (DS)
- Germany's Next Topmodel 2011, (DS)
- Disney Big Hero 6, (DS)
- Mysterious Stars: A Fairy Tale, (DS)
- Mysterious Stars: The Samurai, (DS)
- My Aquarium: Seven Oceans, (DS)
- Mysterious Stars: The Singer, (DS)
- Kim Kardashian: Hollywood - Gameplay, (iPhone-iPod)
- Episode: Choose Your Story - Gameplay, (iPhone-iPod)
- How To Train Your Dragon 2 - Ready To Fly Trailer, (Wii)
- The Settlers - Kingdoms Of Anteria - Announcement Trailer, (PC)
- Entwined - Quick Look Trailer, (PS3)
- Blue Estate - Official Launch Trailer, (PS4)
- Goat Commando 3D Simulator - Gameplay, (iPhone-iPod)
- Munin - Official Launch Trailer, (iPad)


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tag:blogger.com,1999:blog-2932383693193992221.post3282532747705390272..comments2014-12-19T12:19:27.665ZComments on Sepia Saturday: Sepia Saturday 62 : Saturday 19th February 2011Alan Burnetthttps://email@example.com:blogger.com,1999:blog-2932383693193992221.post-63145688547568331222011-02-20T15:20:51.135Z2011-02-20T15:20:51.135ZOops ... forgot to link back to the SS blog. Yest...Oops ... forgot to link back to the SS blog. Yesterday was one of those days!PattyFhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-82685757506560149522011-02-19T23:03:15.262Z2011-02-19T23:03:15.262ZSince I could find no photos of bikes in my parent...Since I could find no photos of bikes in my parents old albums, I went with one that had the word "Bike" in the picture.... making me a sorta-themer? :)~Tracie~http://email@example.com:blogger.com,1999:blog-2932383693193992221.post-46710995867046154462011-02-19T21:00:51.514Z2011-02-19T21:00:51.514ZMore on the Cleage photograph collection with some...More on the Cleage photograph collection with some behind the scenes information and three new shadowy photos.Kristinhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-6682916742285700372011-02-19T19:23:09.628Z2011-02-19T19:23:09.628ZI am new to this, hope this works.I am new to this, hope this works.Rose-Marie Thériaulthttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-39493134336745178482011-02-19T17:33:36.418Z2011-02-19T17:33:36.418ZHi Alan and Kat ... thanks so much for stopping by...Hi Alan and Kat ... thanks so much for stopping by to say hello. I really look forward to Saturdays now!Oregon Gifts of Comfort and Joyhttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-2161039583358069992011-02-19T17:03:22.258Z2011-02-19T17:03:22.258ZA great period photo when bicycles could go as fas...A great period photo when bicycles could go as fast a horse or automobile. The braces are neat too. No bicycle theme for me either. Perhaps the theme could be selected a week before?Mike Brubakerhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-8737476970118389452011-02-19T17:01:18.462Z2011-02-19T17:01:18.462ZOh my gosh what an exciting and action packed them...Oh my gosh what an exciting and action packed theme this week is! Such great detail of what must have been one great day in Ipswich for all!Karen S.http://email@example.com:blogger.com,1999:blog-2932383693193992221.post-26489086216749607402011-02-19T16:46:22.280Z2011-02-19T16:46:22.280ZLove the way the row of handlebars look like cattl...Love the way the row of handlebars look like cattle's horns!Jinksyhttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-22525959202993187252011-02-19T08:36:13.482Z2011-02-19T08:36:13.482Zas a memer, since i like to beat my own drum, a qu...as a memer, since i like to beat my own drum, a quickie, for a change... but i'm working on something that i'll soon share with you.
:)~
HUGZTICKLEBEARhttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-83954495205743230242011-02-19T07:30:35.478Z2011-02-19T07:30:35.478ZI couldn't find any bikes, so I am not a theme...I couldn't find any bikes, so I am not a themer this week. My photo is about a school-boy crush c.1915.
Thanks!Your Genetic Genealogisthttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-45042276885667714732011-02-19T07:23:25.747Z2011-02-19T07:23:25.747ZI assumed that the theme was "wood" as t...I assumed that the theme was "wood" as there is a wooden building in the background and my twp ladies represent the theme in their own way.
Please note the warning from Mr Linky that there will be some down-time next week whilst a new system is installed. It is due to take place on Wednesday night so shouldn't affect us.Alan Burnetthttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-25005604466302228842011-02-19T02:47:14.677Z2011-02-19T02:47:14.677ZOh the bikes are having a rest before pedaled forw...Oh the bikes are having a rest before pedaled forward and onward! My post is something I've spent time pndering this week, it keeps me busy and amused.Pat transplanted to MNhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-31057188062936291852011-02-19T02:43:35.879Z2011-02-19T02:43:35.879ZWonderful photograph Alan! My picture, then and no...Wonderful photograph Alan! My picture, then and now, is pretty much on-topic this weekHowardhttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-4405499629045801812011-02-19T00:39:55.423Z2011-02-19T00:39:55.423ZOver the next few weeks I'll be focusing on ph...Over the next few weeks I'll be focusing on photos from the estate of a man named George Kallman from San Francisco. I know very little about him or his family, but upon his death his photos were unwanted by family members.Tattered and Losthttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-27576536842037049182011-02-18T21:33:10.842Z2011-02-18T21:33:10.842Zi promise not to do any more cookbook-themed posts...i promise not to do any more cookbook-themed posts. I have a great idea for next week that doesn't involve cooking at all.
Nancybarbara and nancyhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-38269204623874070442011-02-18T19:07:51.386Z2011-02-18T19:07:51.386ZSorry couldnt find my bike photo, it was from the ...Sorry couldnt find my bike photo, it was from the 1860's as well! I'll post it again...KarenAlf and Lily Creationshttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-83504480296410300672011-02-18T17:45:00.416Z2011-02-18T17:45:00.416ZI'm a non-themer for right now, lol. I just p...I'm a non-themer for right now, lol. I just posted more Oregon Pioneer history. Thanks so much for thinking this whole project up, by the way. Have a wonderful weekend!

KathyOregon Gifts of Comfort and Joyhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-64886880564726152722011-02-18T17:11:54.976Z2011-02-18T17:11:54.976ZMy SS post this week is doing double duty; it'...My SS post this week is doing double duty; it's on the Acadianeire blog for Sepia Saturday, but it originated with The Poetry Bus, so is posted on Poetikat's Invisible Keepsakes as well.

Some changes have been made for the SS post.

KatKat Mortensenhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-11494076491048170252011-02-18T04:50:25.977Z2011-02-18T04:50:25.977ZOf course when I saw the word Ipswich I thought of...Of course when I saw the word Ipswich I thought of the town 10 miles from here. Thanks for the clarification. I'm an avid biker. Those bikes are very much like today's mountain bikes. Interesting how those handlebars are designed. Those big seats must gave been comfortable! My post is early this week.Crazy as a Cool Foxhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-33719294910004115192011-02-18T00:32:18.415Z2011-02-18T00:32:18.415ZLook. I am usually a very modest bloke, but..........Look. I am usually a very modest bloke, but.......Tonight i got hold of some wonderful photos from the 1950's that nobody has ever seen before!
 Ever!
 This is an exclusive view of images that are unique & very special to me.Please visit and take a look.tonyhttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-2997988894942850672011-02-17T16:14:14.598Z2011-02-17T16:14:14.598ZI've been on a bit of a bike ride this week.I've been on a bit of a bike ride this week.Bob Scotneyhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-86562473699519702962011-02-17T09:48:45.435Z2011-02-17T09:48:45.435ZIm sure I have a old photograph with a bike in it,...Im sure I have a old photograph with a bike in it, I'll have to dig it out for Saturday.Karenhttp://firstname.lastname@example.com:blogger.com,1999:blog-2932383693193992221.post-28967860096761182512011-02-16T22:23:18.764Z2011-02-16T22:23:18.764ZPosting early this week as I'm busy over the w...Posting early this week as I'm busy over the weekend. Haven't managed to follow the theme although I do particularly like it and wish I could have offered something to match it.www.dakotaboo.comhttp://email@example.com:blogger.com,1999:blog-2932383693193992221.post-45096232396653396472011-02-16T21:10:47.049Z2011-02-16T21:10:47.049ZThis photo captures the universal and perennial ap...This photo captures the universal and perennial appeal of bikes. I am surprised how low the handle bars are for this time period. These are not ride in the park cruisers but racers?Paul Chttp://email@example.com


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Parade, visit from Santa mark Merrillville tree-lighting
By Karen Caffarini Post-Tribune correspondent November 18, 2011 10:18PM
Members of the Merrillville High School marching band perform at Merrillville Town Hall Friday night before the lighting of the Christmas Tree along Broadway. | Jeffrey D. Nicholls~Sun-Times Media
Article Extras
Updated: December 20, 2011 8:06AM
MERRILLVILLE — Carter Haynes was waiting to watch his sister perform with the Indiana Ballet Theatre at Merrillville Town Hall on Friday night, but the 4-year-old couldn't stop looking at the jolly bearded man in red and his wife who just started listening to other youngsters' Christmas lists.
"I want big black and green Legos. I want to build a race car," Carter, of Merrillville, said as he sneaked yet another peak at Santa and Mrs. Claus during the Holiday Parade and Tree Lighting event held by the Town of Merrillville and Ross Township Trustee's Office.
Carter wasn't the only excited youngster at the event, which started with a parade from Pierce Middle School to the Town Hall, followed by Christmas music and music by the Merrillville High School Band, lighting of the official tree in the Town Hall parking lot, horse-drawn sleigh rides, refreshments, craft vendors, face painting and, of course, time with Santa.
Cole Viking, 8, of Merrillville, waved to each passing vehicle in the parade, but saved his most enthusiastic wave for Santa and Mrs. Claus who drove in on a truck.
He enjoyed the parade, but had a word of caution for Santa.
"He has to give me presents before I hug him," Cole said. He, too, had his list ready: DS games, Monopoly and other board games, and a race car.
Three-year-old Ziyare Rollins and her cousin Jasmine Ingraham, 11, of Gary, danced to the music of "Jingle Bell Rock" as they waited for the tree-lighting to begin while another cousin, Alexis Wood, 11, watched.
"We're having a wonderful time and getting into the Christmas spirit, Ziyare's mom, Michelle Harper, said.
Nathan Queer, 7, of Merrillville, said he thought this might be the real Santa, but he wasn't sure. He was in the holiday mood anyway, dancing to the music outside and standing in line to see him later inside along with his sisters Nicole Queer, 12, and Natalya Queer, 5.
Inside the Town Hall there was a line for the carriage rides, a line to get hot chocolate and cookies courtesy of the town and township, and a line to see Santa, but no one seemed to mind the wait.
Parents took pictures of their children by some of the many decorated areas in the building and others sat in the council chambers to watch the ballet perform.
Maxine Jones, 7, showed off her face, the top half of which had just been painted white with pink snowflakes added.
"I look like a princess," Maxine, of Merrillville, said softly.
The magic of the season was beginning.


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"The Apple iPod iTunes Anti-Trust Litigation"
Filing 396
MOTION for Protective Order PREVENTING THE DEPOSITION OF STEVE JOBS filed by Apple Inc.. Motion Hearing set for 1/18/2011 10:00 AM in Courtroom 2, 5th Floor, San Jose. (Kiernan, David) (Filed on 12/9/2010)
"The Apple iPod iTunes Anti-Trust Litigation" Doc. 396 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Robert A. Mittelstaedt #60359 firstname.lastname@example.com Craig E. Stewart #129530 firstname.lastname@example.com David C. Kiernan #215335 firstname.lastname@example.com Michael T. Scott #255282 firstname.lastname@example.com JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Telephone: (415) 626-3939 Facsimile: (415) 875-5700 Attorneys for Defendant APPLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION THE APPLE iPOD iTUNES ANTITRUST LITIGATION Case No. C 05-00037-JW (HRL) [CLASS ACTION] APPLE INC.'S NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER PREVENTING THE DEPOSITION OF STEVE JOBS; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF Date: January 18, 2011 Time: 10:00 a.m. Place: Courtroom 2, 5th Floor Honorable Howard Lloyd APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF MOTION PLEASE TAKE NOTICE that Defendant Apple Inc. ("Apple") will and hereby does move this Court for a protective order preventing the deposition of Apple's CEO, Steve Jobs. Plaintiffs cannot show that Mr. Jobs has unique, non-repetitive, firsthand knowledge of information relevant to this antitrust action that is unavailable from other, less burdensome sources. Permitting Plaintiffs to depose Mr. Jobs in these circumstances would unduly burden Mr. Jobs and Apple. The motion is based on this Notice of Motion, the attached Memorandum of Points and Authorities, the Declaration of David C. Kiernan ("Kiernan Decl."), exhibits thereto, and such other matters as may be considered at the hearing. The hearing is set for Tuesday, January 18, 2011, at 10:00 a.m. before the Honorable Howard Lloyd, Courtroom 2, Fifth Floor, in the United States District Court for the Northern District of California, San Jose Division, 280 South 1st Street, San Jose, CA 95113, or as soon thereafter as the parties may be heard. i APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I. MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION To avoid the potential for harassment and undue burden, courts will not permit a deposition of an opposing party's CEO absent specific evidence that the executive has unique personal knowledge of facts unavailable from other sources. Under well-established law governing "apex" depositions, the deposition of Apple's CEO, Steve Jobs, cannot be taken unless Plaintiffs first establish that (1) Mr. Jobs has unique, non-repetitive, firsthand knowledge of the facts at issue in this case and (2) Plaintiffs have exhausted without success other less intrusive discovery methods, such as interrogatories and depositions of other employees. See Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Cir. 1979); Websidestory, Inc. v. Netratings, Inc., 2007 WL 1120567, at *2 (S.D. Cal. Apr. 6, 2007); Celerity, Inc. v. Ultra Clean Holding, Inc., 2007 WL 205067, at *5 (N.D. Cal. Jan. 25, 2007). Plaintiffs have failed to meet this burden. Apple has repeatedly asked Plaintiffs to identify the information they believe Mr. Jobs possesses that cannot be obtained from other, less burdensome sources. In response, Plaintiffs have made only vague references to Mr. Jobs being a "hands-on CEO" and "intimately involved" in issues related to Apple's alleged efforts to monopolize audio download and portable music player markets. Such generic statements fall far short of satisfying Plaintiffs' obligation to demonstrate that the information they seek is relevant and is available only from Mr. Jobs. This is particularly true because Plaintiffs' sole remaining theory of liability is quite narrow. Although Plaintiffs initially asserted broad theories of antitrust liability, their claims have been substantially narrowed by this Court's orders. Plaintiffs' remaining claims rely on the allegation that Apple attempted to maintain a monopoly in the audio download and portable music player markets by issuing updates to FairPlay, Apple's proprietary digital rights management ("DRM") software. FairPlay prevents unauthorized access to and copying of music content in violation of the rights of the record labels that hold the copyrights on that music. Plaintiffs nevertheless claim that updates to FairPlay served no legitimate business purpose. Any relevant information regarding Apple's FairPlay updates, however, has already been provided or can be obtained through deponents and sources other than Mr. Jobs. Apple has APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 produced Apple's documents addressing its updates to FairPlay. Moreover, Apple designated three witnesses in response to Plaintiffs' Federal Rule of Civil Procedure 30(b)(6) deposition notice requesting testimony on topics related to the updates. As of the filing of this motion, two of the witness have been deposed, and both fully addressed all of the issues and questions presented by Plaintiffs' counsel. The third deposition is not scheduled until December 15, but Plaintiffs insisted that Apple move for a protective order before that deposition and before Plaintiffs could determine whether that witness can adequately address any remaining issues related to the updates. Plaintiffs have not shown � and cannot show � that Mr. Jobs possesses any discoverable information not available from these witnesses. Any deposition of Mr. Jobs would be repetitive, at best, and for that reason is not permitted. See Celerity, 2007 WL 205067, at *5 (refusing to permit apex deposition unless the depositions of lower-level employees failed to provide the discovery sought). Apple's request for a protective order should be granted. II. STATEMENT OF FACTS A. Apple and Steve Jobs. Apple is a leading provider of personal computers, mobile communication and media devices, and portable digital music players, and sells a variety of related software, services, peripherals, networking solutions, and third-party digital applications and content. Kiernan Decl. � 2, Ex. 1 at 1. Apple's products and services include Mac computers, iPhone, iPad, iPod, Apple TV, Xserve, a portfolio of consumer and professional software applications, the Mac OS X and iOS, third-party digital content and applications through the iTunes Store, and a variety of accessory, service and support offerings. Id. Apple's innovative products are sold in more than 100 countries, and Apple employs more than 45,000 people worldwide. Id. at 10. Mr. Jobs co-founded Apple in 1976 and is now its CEO and a director. After leaving Apple in 1986, Mr. Jobs returned in 1997 to lead Apple's historic recovery. As CEO, Mr. Jobs is responsible for the management and oversight of Apple's complex global operations. Mr. Jobs also co-founded Pixar Animation Studios, which created several of the most successful featurelength animated films of all time, including Toy Story, Monsters, Inc., and The Incredibles. 2 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Kiernan Decl. � 3, Ex. 2. He served as Pixar's CEO from 1986 until 2006, when Pixar merged with The Walt Disney Company. Mr. Jobs is now a member of Disney's board of directors and serves on a six-person steering committee that oversees Pixar. Kiernan Decl. � 4, Ex. 3. B. The Limited Scope of Plaintiffs' Remaining Claims. The original Complaint was filed on January 3, 2005, with a Consolidated Amended Complaint filed on May 19, 2007. For the first four years of this action, Plaintiffs' claims were focused on a "tying" theory that Apple violated Section 1 of the Sherman Act by using its DRM software, FairPlay, to prevent piracy of music downloaded from Apple's iTunes Store or downloaded to Apple iPods. Plaintiffs claimed that FairPlay illegally "tied" content purchased from the iTunes Store to iPods and locked consumers into purchasing iPods rather than other portable media devices. The Court rejected this theory last year and dismissed Plaintiffs' Section 1 claim. The Court held that "[t]he increased convenience of using the two products together due to technological compatibility does not constitute anticompetitive conduct under either per se or rule of reason analysis." (Order Granting Defendant's Motion for Judgment on the Pleadings, October 30, 2009, Docket No. 274 ("Order Granting Judgment on the Pleadings") at 9-10.) The original Complaint further alleged that the same "tying" conduct also violated Section 2 of the Sherman Act. The Court, however, ruled that its dismissal of the tying claim applied equally to Plaintiffs' Section 2 monopolization claim. The Court ruled that the alleged technological tie between Apple products "when they were first introduced to the market" was, "without more, . . . not anticompetitive" and thus does not constitute exclusionary conduct for a monopoly claim. (Order Decertifying Classes, December 21, 2009, Docket No. 303, at 2.) The Court accordingly directed Plaintiffs to file an amended complaint to clarify "what actions they allege Apple took to maintain monopoly power beyond initial technological relationships between its products." Id. These rulings establish that it was lawful for Apple to choose its own DRM software, even if the result was to create "technologically-related products" that are allegedly "incompatible with the products offered by competitors." (See Order Granting Judgment on the Pleadings at 10.) 3 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 As a result, Plaintiffs now challenge only Apple's updates to FairPlay, alleging that they were not for legitimate business reasons such as preventing music piracy, but were designed to "entrench its monopolies through the use of unnecessary, non-improving software updates intended to exclude competition and further restrict consumer choice." (Plaintiffs' Memorandum in Opposition to Apple's Motion to Dismiss, March 22, 2010, Docket No. 345, at 6; see also Amended Consolidated Complaint, January 26, 2010, Docket No. 322, at 8-10.) Under controlling Ninth Circuit precedent, a threshold liability issue is whether the software updates were product improvements. Allied Orthopedic Appliances, Inc. v. Tyco Health Care Grp. LP, 592 F.3d 991 (9th Cir. 2010). If so, the Section 2 claim is without merit. Under Tyco, the Court does not engage in balancing the "benefits or worth of a product improvement . . . against its anticompetitive effects." Id. at 1000. So long as the change improves the product, the change is "necessarily tolerated by the antitrust laws." Id. Tyco also shows that allegations of anti-competitive intent do not change the result. The Tyco plaintiffs pointed to evidence that Tyco "hoped its new technology would constitute a barrier to entry" by its competitors. Tyco, 592 F.3d at 1001. But the Ninth Circuit held that "[s]tatements of an innovator's intent to harm a competitor through genuine product improvement are insufficient by themselves to create a jury question under Section 2" because "even legitimate product improvement can have the effect of harming or even destroying competitors." Id. C. Plaintiffs' Request to Depose Apple's CEO Steve Jobs. Although this case has been pending for more than five years, on November 3, 2010, Plaintiffs raised for the first time the issue of deposing Mr. Jobs. Kiernan Decl. � 5, Ex. 4. Since that time, the parties have had a series of meet-and-confer discussions regarding Plaintiffs' requested deposition of Mr. Jobs. Apple explained that given the limited issues remaining in the case, Mr. Jobs's deposition is unnecessary and relevant discovery is available through less burdensome means. Kiernan Decl. � 6, Ex. 6. Apple asked Plaintiffs to explain the reasons justifying Mr. Jobs's deposition. Id. Plaintiffs provided only a vague, conclusory response, stating that Mr. Jobs is a "hands-on CEO" and "was intimately involved in issues related to Apple's efforts to monopolize the online 4 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 music and portable music player markets." Kiernan Decl. � 7, Ex. 7. Plaintiffs also claimed that they want to depose Mr. Jobs regarding certain emails and other documents, which Plaintiffs refused to identify but which they claimed relate to Apple's market share and licensing of FairPlay. Id. Misstating the standard for allowing an apex deposition, Plaintiffs suggested that a protective order will be granted only when the witness has "no first-hand knowledge" of the facts at issue. Id. To the contrary, an apex deposition is permitted only if the executive has unique, firsthand knowledge of relevant information that is not available through other, less burdensome means, such as depositions of other employees or interrogatories. Apple explained that Plaintiffs have already obtained documents, and would soon depose those Apple witnesses with firsthand knowledge, regarding the limited issues remaining in the case. Kiernan Decl. �� 8-10, Exs. 6, 8. In fact, to date Apple has produced over one million pages of documents, including documents describing FairPlay updates. Apple also produced source code for FairPlay and the updates thereto. The documents describe, in both highly technical detail and general terms, FairPlay's architecture and technology used by Apple's engineers. Kiernan Decl. � 8. In response to Plaintiffs' Rule 30(b)(6) deposition notices, Apple has also identified the Apple employees with firsthand knowledge of the facts relating to Apple's FairPlay updates who can address Plaintiffs' allegations that the updates were "unnecessary," "non-improving," and "intended to exclude competition." Kiernan Decl. � 10, Ex. 8: � Jeffrey Robbin: Mr. Robbin is Apple's Vice President of iTunes who has firsthand knowledge regarding development of the iPod, iTunes client, the iTunes Store, updates to iTunes, updates to FairPlay included in iTunes 4.7 that are the focus of the amended complaint, and communications with the various record labels regarding security breaches and updates to FairPlay. Mr. Robbin was designated to provide testimony relating to communications with content providers regarding Apple's updates to FairPlay. Augustin Farrugia: Mr. Farrugia is Apple's Senior Director of DRM Technologies with responsibilities for FairPlay engineering, design, and development. Mr. Farrugia was designated to provide testimony relating to updates made to FairPlay in the iTunes versions following version 6.0. Dave Heller. Mr. Heller is Apple's Director of iTunes Client Engineering and was responsible for FairPlay engineering and development prior to the hiring of Augustin Farrugia. He has firsthand knowledge regarding updates to iTunes and updates to FairPlay included in iTunes 4.7 that are the focus of the amended complaint. Mr. Heller was designated to provide testimony relating to the relationship between iPod 5 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) � � 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Id. firmware and iTunes software and updates made to FairPlay in iTunes versions 6.0 and earlier. The parties' meet-and-confer efforts were unsuccessful. Plaintiffs scheduled the depositions of the Apple employees identified as having firsthand knowledge of the facts at issue for December 3, 8 and 15. But without waiting to exhaust those witnesses' knowledge of the relevant issues, Plaintiffs continued to insist on Mr. Jobs's deposition. Kiernan Decl. � 11. D. Apple's 30(b)(6) Designees Have Complete, Firsthand Knowledge of All the Relevant Information Plaintiffs Allegedly Seek from Mr. Jobs. Apple agreed to make its witnesses with firsthand knowledge regarding FairPlay's updates available for full-day depositions, and even agreed to allow Plaintiffs to take up to nine hours of testimony per witness to give Plaintiffs adequate time with each witness. Kiernan Decl. � 10, Ex. 8. The depositions of Messrs. Robbin and Farrugia have now concluded. These witnesses were prepared and responded fully to Plaintiffs' questions. Plaintiffs opted not to take the full nine hours with either of these witnesses. Plaintiffs have not, nor can they, identify any information they solicited from Apple's 30(b)(6) designees but could not obtain because such information is uniquely known to Mr. Jobs. Kiernan Decl. � 12. The deposition of Apple's third 30(b)(6) designee, Mr. Heller, is scheduled for December 15. Apple proposed to Plaintiffs that this protective order motion be filed, if at all, after Mr. Heller's deposition. As Apple explained, Plaintiffs would then be in a better position to evaluate whether they still believed they need Mr. Jobs's deposition, or whether, as Apple believes, any testimony that Mr. Jobs could provide would be duplicative of the testimony of Apple's other employees. Kiernan Decl. � 13, Ex. 9. Plaintiffs rejected that schedule and insisted that Apple file this motion for protective order by December 9. Kiernan Decl. � 14, Ex. 10. III. ARGUMENT A. Depositions of a Corporation's Top Executive Are Disfavored. Courts have long recognized the potential for harassment and burden in depositions of the senior-most executives of large corporations. "Virtually every court that has addressed deposition 6 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 notices directed at an official at the highest level or `apex' of corporate management has observed that such discovery creates a tremendous potential for abuse or harassment." See Celerity, 2007 WL 205067, at *3; see also Serrano v. Cintas Corp., 2010 WL 2490775, at *2 (E.D. Mich. June 10, 2010). The court in Serrano explained that "the unique and important position of chief executive officers" justifies the protection courts must offer these executives pursuant to the "apex" doctrine: [T]he well recognized doctrine [provides] that courts will protect individuals at the apex of a corporate hierarchy from deposition when such individuals lack personal knowledge regarding the litigation, or when the requested information could be garnered from equally or more knowledgeable subordinates. The doctrine recognizes the unique and important position of chief executive officers, and the potential for harassment and abuse inherent in subjecting them to discovery burdens in the absence of a showing that the individual possesses relevant evidence which is not readily obtainable from other sources. Id. (citations omitted). The rationale for precluding apex depositions set forth in Serrano is particularly applicable where, as here, the defendant is one of the largest companies in the world, offers diverse products and services, and operates in some of the most fiercely competitive markets. Moreover, Mr. Jobs's status as one of the world's most recognizable business leaders increases the potential that harassing discovery will be directed at him. Courts have the authority to prevent unnecessary depositions of chief executives. Federal Rule of Civil Procedure 26(c) provides that the "court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense." Rule 26(b)(2) specifically requires the court "to limit discovery if it determines that the discovery sought is obtainable from other sources, that is, those that are more convenient and less burdensome." Fed. R. Civ. P. 26(b)(2); see also Mulvey v. Chrysler Corp., 106 F.R.D. 364, 366 (D.R.I. 1985). Pursuant to this authority, courts have defined well-established criteria for determining when a senior executive can be deposed. A party cannot depose an executive at the apex of the corporation unless the party seeking the deposition establishes (1) the individual has unique, nonrepetitive, firsthand knowledge of the facts at issue in the case, and (2) the party seeking the deposition has exhausted without success other less intrusive discovery methods, such as 7 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 interrogatories and depositions of lower-level employees. See, e.g., Salter, 593 F.2d at 651; Websidestory, Inc., 2007 WL 1120567, at *2; Cardenas v. Prudential Ins. Co. of Am., 2003 WL 21293757, at *1 (D. Minn. May 16, 2003) ("[C]ourts frequently restrict efforts to depose senior executives where the party seeking the deposition can obtain the same information through a less intrusive means, or where the party has not established that the executive has some unique knowledge pertinent to the issues in the case."). A party seeking the deposition of a chief executive cannot defeat a motion for protective order merely by establishing that the executive possesses relevant information, if such information is also known and available through other means. See Celerity, 2007 WL 205067, at *4-5 (granting protective order even though executives had personal knowledge of relevant facts because such knowledge was not unique to those executives); Gutescu v. Carey Int'l, Inc., 2003 WL 25589029, at *1-2 (S.D. Fla. June 23, 2003) (barring deposition of CEO notwithstanding that the CEO was listed on a press release relevant to the issues in the case, finding that the plaintiff could take a Rule 30(b)(6) deposition to try to obtain the discovery through other means); Porter v. Eli Lilly & Co., 2007 WL 1630697, at *3 (N.D. Ga. 2007) (the party seeking the deposition must show that "the executive would have personal knowledge of the events in question and a plaintiff has no other means of obtaining the information"). Under this well-established law, the requested deposition of Mr. Jobs is improper. B. Plaintiffs Cannot Establish That Mr. Jobs Has Unique Knowledge of Facts Relevant to the Issues Remaining in This Case. Apple repeatedly asked Plaintiffs to identify the topics of which Mr. Jobs has unique, firsthand knowledge sufficient to justify this apex deposition. In a written response, Plaintiffs offered only three conclusory and insufficient reasons for their purported need for the deposition: Mr. Jobs (1) is a "hands-on" CEO; (2) was intimately involved in issues related to Apple's alleged efforts to monopolize the audio download and portable music player markets; and (3) wrote certain unidentified emails and other documents regarding market share and issues related to licensing of FairPlay. Kiernan Decl. � 7, Ex. 7. None of these reasons warrants permitting Mr. Jobs's deposition to proceed. 8 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 First, Apple agrees with Plaintiffs' characterization that Mr. Jobs is a "hands-on CEO" who is actively involved in the management of Apple. The question, however, is not whether the executive is an active manager but whether the executive possesses discoverable information not available from other sources. Thus, the rule against apex depositions is not limited to absentee CEOs. Indeed, the more active a CEO the more likely that a deposition will interfere with the day-to-day operations of the company. Second, Plaintiffs' thin assertion that Mr. Jobs was "intimately involved" in the issues relating to Plaintiffs' monopolization claim has no support or explanation. And even if that assertion were true, Plaintiffs do not claim that such "intimate knowledge" is unique to Mr. Jobs. Finally, Apple has already produced documents relating to its market share and the issues relating to the licensing of FairPlay and has provided deponents to testify on those issues. Plaintiffs have not identified any information regarding market share or licensing that can be obtained from Mr. Jobs but not elsewhere. Moreover, as Apple pointed out in meet-and-confer discussions, Apple's licensing practices with respect to FairPlay are not at issue in this case because the issues have been limited to Apple's software updates. Kiernan Decl. � 6, Ex. 6. A deposition of Mr. Jobs would not result in any unique, firsthand knowledge of any issues that remain relevant to this action. C. The Information Plaintiffs Seek From Mr. Jobs Is Available From Apple's Other Witnesses. An apex deposition of a chief executive will be permitted only if lower-level employees are unable to provide relevant information and the requesting party can establish that such information is known firsthand by the chief executive. See Stone v. Morton Int'l Inc., 170 F.R.D. 498, 504 (D. Utah 1997) (granting a protective order until plaintiff had taken a Rule 30(b)(6) deposition and established that the apex witness was the logical source for the evidence). Plaintiffs, nonetheless, insisted on Mr. Jobs's deposition even before discovering what information Apple's other employees would provide. Apple identified three employees with information relevant to Apple's FairPlay updates and designated them as persons knowledgeable to testify pursuant to Rule 30(b)(6). Plaintiffs 9 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 have now concluded two of those depositions without any indication that Apple's witnesses were not fully prepared or that their testimony was insufficient. Kiernan Decl. � 12. These employees have adequately responded to Plaintiffs' questions, and any examination of Mr. Jobs would be redundant at best and is not permitted. And Plaintiffs may not argue that they failed to ask questions of these employees and, as a result, are entitled to explore those issues with Mr. Jobs. Failure to ask relevant questions during lower-level depositions does not provide a basis to assume the CEO may possess the answers to the questions not asked. See Reif v. CNA, 248 F.R.D. 448, 453-54 (E.D. Pa. 2008) ("The depositions, thus far, have failed to demonstrate the deponents lack the information, especially when the pertinent questions have not been asked."). The deposition of Apple's third 30(b)(6) designee is scheduled for December 15, but Plaintiffs insisted that Apple move for a protective order before that deposition and before knowing whether that witness can adequately address the issues related to the updates. Kiernan Decl. �� 13-14, Ex. 10. Apple is confident that, like Apple's two other designees, this witness will adequately address the issues Plaintiffs would seek to explore regarding Apple's software updates and that Plaintiffs will be unable to identify any information possessed only by Mr. Jobs. Plaintiffs' insistence that Mr. Jobs's deposition go forward without knowing whether the evidence they seek can be obtained from depositions of other employees is precisely what the apex deposition rule seeks to avoid. See Stelor Prods., Inc. v. Google, Inc., 2008 WL 4218107, at *4 (S.D. Fla. Sept. 15, 2008) (denying motion to compel depositions of Google founders Sergey Brin and Larry Page where opposing party had not first taken Rule 30(b)(6) depositions on identical topics, stating that "if questions remain unanswered after [30(b)(6) designee's] deposition, then plaintiff would be permitted to depose both Brin and Page on the limited issues yet unanswered.") IV. CONCLUSION Plaintiffs cannot meet the high standard for an apex deposition of Apple's CEO. Plaintiffs cannot show that Mr. Jobs has unique, non-repetitive, firsthand knowledge of the facts at issue in the case, and the information Plaintiffs seek is readily available from other sources. Accordingly, Apple respectfully requests that the Court grant a protective order preventing the deposition of Mr. Jobs. 10 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 11 APPLE'S MOTION FOR PROTECTIVE ORDER PREVENTING DEP. OF APPLE CEO STEVE JOBS CASE NO. C 05-00037-JW (HRL) SFI-656655v1 Dated: December 9, 2010 By: /s/ David C. Kiernan JONES DAY 555 California Street, 26th Floor San Francisco, CA 94104 Attorneys for Defendant APPLE INC.


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