I theorize that, since layoffs are often used to lower total salaries paid out for a given number of positions by firing several times as many people as necessa

I theorize that, since layoffs are often used to lower total salaries paid out for a given number of positions by firing several times as many people as necessary, and then forcing positions that have to be refilled to only hire lower-skill / lower-pay workers. If that theory holds, then Meta’s blocklist will hold every worker ever fired by Meta during a salary-reduction layoff, to ensure that the pay reduction affects rehiring. Which would set up Meta to be vulnerable to an age discrimination lawsuit, since layoffs of people with “excellent performance” records would likely be constructed from salary pay tiers, and thus disproportionately affect people who are with Meta longer, and thus are older. The discovery questions are twofold, and could be presented to a judge by Meta in order to evaluate the merits of either continuing or cancelling a discrimination lawsuit — negating any objections Meta might file about revealing sensitive workplace data. 1. What is the age distribution of the Meta block list, in percentages only, with a bucket size of 5 years started at age <17, then 18-22, 23-27, etc? 2. What quantity of workers were added to the Meta block list in the six months preceding and following each of Meta’s last few layoffs, truncated to the first significant digit? i.e. 14999 is reported as 10000-19999, 622 is reported as 600-699, etc. Were I pursuing such a thing, which I am not, those are the class-action discovery questions that I feel would rapidly expose whether a lawsuit could proceed or not. (I am not your lawyer, this is not legal advice, etc.)