Apple wants devices imaged in 30 days, and the calendar is the whole argument

Sequencing is where the leverage sits. The defendants have already agreed Apple can take the depositions it wants; their counter is that each witness sits once, presumably at the end of fact discovery ^[10]. Same event, different value. Apple's stated reason for hurrying is that the facts it needs are dissipating and outside its control ^[12], and a single deposition after months of document production is the version of that event least likely to surprise anyone.

Forensic imaging is the request that decays fastest ^[2]. An image is a snapshot of a machine or an account on the day it is taken, and every week an order slips, the snapshot describes something a little further from the period in dispute. That is why the 30-day and 50-day clocks matter more than they look: the relief Apple is asking for is partly evidentiary preservation dressed as discovery scheduling ^[3].

The narrowing is the most revealing paragraph in the filing. Apple moved its document window to August 1, 2023, describing that date as roughly six months before Mr. Tan left for OpenAI ^[8], which puts the departure around February 2024 ^[11]. So the requests are not aimed only at what happened after the resignation. They reach into the months while the employee was still inside the company, which is where recruiting conversations and file access would live if Apple's theory is right.

OpenAI and its co-defendants read the same requests as an attempt at an improper peek at competitive product plans and strategies, untethered from the injunction Apple filed for a day earlier ^[7][4]. That objection depends entirely on how the court reads Apple's theory of harm, which is that every day without an injunction lets OpenAI embed knowledge of the allegedly stolen material into hardware development ^[5]. If the secrets are alleged to be inside the current plan, the plan is evidence; if they are not, Apple is shopping. A judge cannot separate those two readings without looking at some of the material, which is itself an argument for front-loading a narrow slice of it.

The mootness fight is the small one with the large effect. Defendants say ordinary discovery overlaps the proposed timeline, so no order is needed ^[6]. Apple says overlap is beside the point and that without an order the defendants will object, delay, and condition discovery on tangential reciprocal demands ^[9]. Stripped of the briefing voice, Apple is asking the court to make boilerplate objections expensive in week one rather than month six.

For anyone staffing a hardware team out of a competitor, the number to note is not 30 or 50. It is August 1, 2023 ^[8]: whether a court will let a plaintiff start reading email six months before the resignation letter.