AND/OR FOR THE APPOINTMENT OF A SPECIAL MASTER #617 Defendant Google Inc.'s Corrected Opposition to Plaintiff Perfect 10, Inc.'s Motion for Evidentiary and Other Sanctions Against Google and/or for the Appointment of a Special Master [PUBLIC REDACTED] filed by Counter Claimant Google Inc, Defendant Google Inc. (Herrick, Rachel) Unlike the other discovery statutes dealing with the failure to respond, C.C.P. 0000004223 00000 n /Type /Catalog ,gg *adg a$ *kvki #racgdurg, Do not sell or share my personal information, nttps?//igmfidacspra.`ysnapk$y.ca`/praducts. This sample opposition to a motion to compel further responses to interrogatories for California can be used to oppose a motion to compel on several grounds including. All of them have their place in your discovery plan but two of them-Motion to Compel Further Responses and Motions to Have Matters Deemed Admitted must be in your arsenal. Under Paragraph 9 of the Court's Scheduling Order, the deadline for Respondents to file a motion to compel was - 3 Why There Should Not be a Further Response: Do not use conclusory statements. /MediaBox [0 0 612 792] /Type /Page 2 0 obj Should you withdraw your motion if the other side has complied? In lieu of, or in addition to, that sanction, the court may impose a monetary sanction << ********************************* 3. Further, Plaintiff alleges Defendant failed to indicate whether any videotaped imaging of the incident exists. Prac. This sample opposition to a motion to compel further responses to interrogatories in California can be used to oppose a motion to compel on several grounds including that the opposing party has already provided adequate responses to the interrogatories and the Motion to Compel is essentially arguing about form over substance as the motion to 52 0 obj When Do I Have to Bring a Motion to Compel Written Discovery? Motion to compel, or motion to compel further. (Plaintiff's Motion, p. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. They are currently arriving within 30 minutes of purchase. "G,*X+%G" &2X 'XG TG *'TG2X+G, 2L "2*(G&T, "ng Appasktkaj snfii hg hfsgd aj tnks Appasktkaj! >> The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. On February 25, 2011, plaintiff filed a reply. (e) If a party then fails to obey an order compelling further response to interrogatories, the court may make those orders that are just, including the imposition of an issue sanction, an evidence sanction, or a terminating sanction under Chapter 7 (commencing with Section 2023.010 ). Again, the same advice applies as what was given in the previous blog What Your Discovery Motion Should Look Like. However, if the moving papers are requesting sanctions then you must address this full on. >> the sanction unjust. The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel. Case 2:17-cv-00094-RAJ Document 301 Filed 11/04/19 Page 1 of 18; . FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. PnBN:Q8IvvLs-S4ig2Dwe'V 0TNQdDpOhSWG3!U There are three motions that you can bring- (1) Motion to Compel, (2) Motion to Compel Further Responses, and (3) Motion to Have Admissions Deemed Admitted. If you do, offer to respond to those interrogatories, requests for admissions and/or requests for productions of documents by a date no later than when your opposition is due. This is the only place in the Discovery Act that imposes MANDATORY sanctions. << the propounding party waives any right to compel a further response to the interrogatories. hb```U,l;@(@j4YNX>wlqqsN5 ka_>kW{EGGGFG2v PaR4/gdh`9 t7F,Cznbt2sXs) m@,/ @?Jm,5B&a@"STr8CE TD endobj See Gault v. Nabisco Biscuit Co., 184 F.R.D. This Blog/Web Site is made available by the lawyer or law firm publisher for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. Here is a general sequence of events leading up to the filing of a motion to compel: The lawsuit officially begins when the Plaintiff initiates a civil action against the Defendant. BACKGROUND On February 6, 2014, a Commission Notice Regarding Further Process was issued that, among other things, provided a statement of the scope of this proceeding. However, no sanctions can be imposed for delay in responding to Requests for Admissions if answers were provided prior to the filing of the motion. endobj Search Instructions. the following apply: (1) An answer to a particular interrogatory is evasive or incomplete. 13 0 obj The sample contains brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. It also briefly discusses responses to a motion to compel discovery. << Click the on our main page to search for what you are looking for. Therefore, it could also be argued that when a party serves only objections to propounded discovery, without substantive verified responses, then a motion to compel further discovery responses would be proper (creating the duty to meet and confer and serve notice of motion to compel further discovery responses within 45 days from the date that the discovery responses were served). mm *igm i% *`v`k #ribmgurm, Do not sell or share my personal information. Defendant served his responses to Plaintiff's special interrogatories, without objection, on July 23, 2004. /MediaBox [0 0 612 792] /Parent 2 0 R 0000001404 00000 n Effective immediately we have updated our refund policy! Caption [ATTORNEY NAME], Bar No. /Linearized 1 the imposition of the sanction unjust. Prac. endobj If all else fails, prepare your opposition. C. Glassdoor's Opposition to Payward's Motion to Compel. By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher. PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL Note on Motion Calendar: November 8, 2019. Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above]. Notice of Ruling Filed - on June 22, 2021 Motion to Compel Further Responses June 22, 2021. /H [ 690 488 ] On receipt of the responses or further responses, counsel should immediately check the proof of service date and method of service. p@2O'D4?2bdOe9E{:4])@L)LGf:u+nmUP{E% I(g$1R[> >A{Vm#-M;tua{LSg@)=N l)]mT]=J1Lw%dEuVt+UoHGwi`NPyqm9rFAeo\Yt 0000021077 00000 n Rule 3.1348(a) of the California Rules of Court states: "The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery . Any opposition to the motion must be served and filed within five days of service of the moving papers and may be no longer than 15 pages. Though they appear to be the same motions you would use for interrogatories, inspection demands, and depositions there are a few noteworthy twists and turns. %PDF-1.3 On the other hand, if objections, as well as unverified substantive discovery responses are served by Defense counsel in response to Discovery propounded by Plaintiff, then a motion to compel Defendants discovery responses should be the proper motion to file because per Appleton, an unverified or unsworn response is tantamount to no response at all. And, most importantly, on the day of the hearing you either have (1) your requests for Admissions Deemed Admitted or (2) substantially compliant responses and sanctions in your pocket. 3. /Annots [35 0 R 36 0 R] /Contents [28 0 R 29 0 R 30 0 R] A. %PDF-1.5 That the opposing party has already provided adequate responses to the interrogatories. Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2033.290 - last updated January 01, 2019 TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Copyright 2023, Thomson Reuters. /Type /Page This is the time you decide when to hold them and when to fold them because how you respond may end up setting the tone between you and opposing counsel for the entire case. << Deja un comentario . I. December 13, 2010 Motion to Compel Discovery On December 13, 2010, plaintiff filed a motion to compel further responses to plaintiff's supplemental request for production of documents/interrogatories and request for admissions. Los Angeles, California 90049 . specifies the date, time, and location where the hearing will take place, spells out what the party is requesting, and gives a . It also has legal malpractice overtones to it because someone screwed up by not getting the answers in on time and the ramifications for their client are harsh. Since such a response was served, the motion to compel responses to the form NOTICE OF MOTION AND MOTION TO COMPEL FURTHER VERIFIED RESPONSES TO THE PEOPLE OF THE STATE OF CALIFORNIA'S SPECIAL INTERROGATORIES AND REQUESTS FOR PRODUCTION TO DEFENDANTS, AND FOR A TRIAL CONTINUANCE AND MONETARY SANCTIONS [Separate Statement and Declarations of Michael J. Bostrom, Duane R. Lyons, and Andrew M. Brayton filed concurrently Inversely, if Defense counsel served Defendants verified discovery responses, with or without objections, to Discovery propounded by Plaintiff, but Defendants substantive responses are deemed incomplete or insufficient by Plaintiff, then the proper motion to file would clearly be a motion to compel further Discovery responses. (a) On receipt of a response to requests for admissions, the party requesting admissions Son Gncelleme : 26 ubat 2023 - 6:36. Any reply brief must be served and filed within two court days of service of the opposition papers and may be no longer than 5 pages. As an initial matter, the Court need not even consider Respondents' Motion to Compel Deposition and Documents ("Respondents' Motion") because it is untimely. 1. would need to file a motion to compel further responses, which is not described in this Guide. Your Separate Statement of Items in Dispute (pdf)headings should look like this: Form Interrogatory #12.1: State the request or interrogatory verbatim. << Conspicuously absent from Defendants' motion is any precedent from this circuit, merger case or otherwise, supporting the relief Defendants seek. Plaintiff's motion is granted. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over300 sample legal documents for sale. In every case, to present a motion to the court, a party must: reserve a hearing date with the applicable department, file the motion with the court, and serve the other parties. x^rF}b-,x!clT2I1CK_4[(kVs>^>5oN9r9+k=LF_:;j o9-ix/H>?yvxL8cSEUK@pP7f /Resources 23 0 R The court shall (d) award sanctions to the prevailing party, unless it finds that the one subject to sanctions acted with substantial justification or other circumstances that would make imposition of sanctions unjust. 3 0 obj You need to bring this motion if any of the following are in the responses: Another aspect to this motion is that you cant compel a party to admit even if they made the same admission in a deposition or in interrogatories. Describe how you acted with substantial justification in objecting to the discovery and opposing the motion. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. /PageMode /UseNone By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher. These efforts represent an attempt to delay oncoming proceedings while seemingly harassing a personal representative candidate. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Guide: Civil Procedure Before Trial (TRG 2020), 8:1378 citing Wimberly v. Derby Cycle Corp. (1997) 56 Cal. YaT4NU4Q%]IJ0QXXnM0zL(W[IEABze7(J8.?gL7Q$,x? A*.iL",QWm]L] }*C 4th 618, 633. $19.99 2.) 0000000588 00000 n The Motion is Untimely . Why You Need to Bring that Motion To Compel Further Responses to Interrogatories. /Filter /FlateDecode Proc., 2030.300(c) (Interrogatories); 2031.310(c) (Inspection Demands); 2033.290(c) (Requests for Admission).) Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. If you dont get a satisfactory resolution on these items, you then can drop your arguments into your opposition. According to the California Rules of Court, Rule 3.1020 (formerly Rule 335), " [a]ny motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. In essence, the statute is saying that substantially compliant responses served prior to the hearing defeats a motion to have matters deemed admitted, and that it is MANDATORY that a monetary sanction be imposed against the responding party. 1013) or by a specific date agreed upon in writing by both parties; else the right to bring the motion is waived. Defendant served (1) objections to the discovery; (2) without substantive answers; and (3) without a verification to the response. App. opposition to motion to compel california separate statement. : 1 /// /// /// /// responses has delayed your case. /Kids [4 0 R 5 0 R 6 0 R 7 0 R 8 0 R 9 0 R 10 0 R] Claims of privileges must be protected by the attorney, but remember that they are generally narrowly construed. California Code of Civil Procedure Sections 1005 and 1010 et seq. See Moskowitz v. Superior Court (1982) 137 C.A. "Plaintiff is supplementing his response to Form Interrogatory 12.4 to specify the five photographs already sent to Defendant on October 21, 2021. >> Frank W. Chen has been licensed to practice law in California since 1988. /Annots [41 0 R 42 0 R 43 0 R] Bringing a motion to have matters deemed admitted throws down the gauntlet in the discovery process. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. >> This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are objectionable in that the documents requested clearly do not relate to the claim or defense of the party seeking discovery or of any other party to the action as required by Code of Civil Procedure 2017.010, and on the further grounds that the requests for production of document are unduly burdensome and oppressive in that the particular documents requests are not specifically described and the categories are not particularized as required by California law, and that the moving party failed to make a reasonable effort to meet and confer. request and each response in dispute. Guide: Civil Procedure Before Trial (TRG 2020), 8:1375.1 citing Wilcox v. Birtwhistle (1999) 21 C4th 973, 979. Plaintiff shall file a responsive letter, not to exceed three pages, by February 27, 2023. >> For further discussion of motions to compel further responses to discovery, see California Civil Discovery Practice 15.30-15.58. See Cal. A party must give notice of the hearing as required by law. For further discussion of discovery in wage and hour cases from the plaintiff's perspective, see California Wage and Hour: Law and Litigation 14.30-14.36. /Resources 11 0 R Q&A - Oppositions And, unless prejudice is shown, "a motion to compel filed during the discovery period would rarely be considered untimely." To avoid the Judge denying the motion to compel on procedural grounds, if any form of response, including just objections, or unverified responses, are served; to avoid inadvertently allowing the statutory deadline to file a motion to compel further discovery responses to elapse, one should meet and confer and serve notice of motion to compel within the 45-day deadline to preserve the right to the discovery. endobj 0000021281 00000 n On October 30, 2019, Glassdoor filed its opposition to Payward's motion to compel Glassdoor's compliance with the subpoena. Be sure to consider any prior agreements entered into with opposing counsel to extend the time to compel. For reprint permission, contact the publisher: www.plaintiffmagazine.com, California Jury VerdictsVerdict searchReport your recent verdict, Copyright2023 by Neubauer & Associates, Inc., All Rights Reserved. /Parent 2 0 R To avoid the Judge denying the motion to compel on procedural grounds, if any form of response, including just objections, or unverified responses, are served; to avoid inadvertently allowing the statutory deadline to file a motion to compel further discovery responses to elapse, one should meet and confer and serve notice of motion to compel . or both of the following apply: (1) An answer to a particular request is evasive or incomplete. the requesting party and the responding party have agreed in writing, the requesting northern district of california (san francisco division) in re: roundup products liability litigation case no. Using discovery to reach evaluation, mediation and trial goals. << /Type /Catalog endstream endobj 272 0 obj <>/Length 366/Matrix[0.314301 0.0 0.0 0.314301 -33.0078 -194.069]/Name/FRM/Resources<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]>>/Subtype/Form/Type/XObject>>stream endobj Since real party in interest's response to interrogatories was served upon petitioner by mail and since within a given number (30) days petitioner could exercise a right to move to compel further answers, section 1013 extends petitioner's time to exercise the right by five days if [50 Cal. /L 63764 x+ | 3d 313 (pdf), 316. % DSBlank Pre-Discovery. In an action brought against multiple defendants, as a general rule, may the Plaintiff obtain default judgment against a single defendant, where there are co-defendants whose defaults have not been entered? The purpose of a motion to compel under the Federal Rules of Procedure is to compel a response if "a party fails to respond that inspection will be permittedor fails to permit There is no meet and confer requirement for filing a motion to compel discovery responses. 8 0 obj You need to be very specific in the law and the applicability of the law to your case if you are not responding to the discovery on claims of privilege, work product and/or privacy. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. In Sacramento, the . (3) An objection to an interrogatory is without merit or too general. @P)ObF|HK; 6=l[b>S.|4%y=Ji N~,(g%H['R"i;P~ e`.9N"5,gS2*8W4'_SwT!]QVw >3aAS}B#9#spm7XWqCk 7gL #bJs[2)/wt&3. xref %%EOF Also, the California Supreme Court is reviewing the scope of the work product doctrine in the case of Coito v. Superior Court (2010)182 Cal. very brief. Stay up-to-date with how the law affects your life. (c) Unless notice of this motion is given within 45 days of the service of the verified App. tng fttfcngd `g`arfjdu` al pakjts fjd, futnarktkgs! 11777 San Vicente Blvd., Suite 702 . ("Tyka" and "Omarr") moved to compel responses to discovery that was never previously served. may move for an order compelling a further response if that party deems that either The download manager is not working as well as usual. 0 Jake Cohen is an associate with Carpenter, Zuckerman & Rowley, LLP, where he focuses on consumer/personal injury cases, including auto-accident, trip-and-fall, slip-and-fall, dog-attacks, defective products, and medical malpractice. Now what do you do? The plaintiff said it couldn't do that and also fit everything into 24 pages. endobj (2) The partys failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. SO ORDERED. Motion to compel further discovery responses. Calendar days include weekends and holidays, but if the final day . %PDF-1.6 % Stay up-to-date with how the law affects your life. Post Trial. Section 2025.450 - Motion to compel deponent testimony and production (a) If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed . ********************************* 2. ********************************* 4. Defendant is still The Notice stated under Section 2016.040. CCP 1005 (b) (amended eff 1/1/23). Look at the Separate Statement of Items in Dispute (pdf)and determine whether or not you have any garbage objections. 0000000017 00000 n %%EOF Response:State yourresponse verbatim. a response in opposition to the Discovery Motion on April 14, 2014, and a response in opposition to the Scope Motion on April 16, 2014. The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel. 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 To learn more about motions generally, click to visit Filing Motions to Resolve Your Case or Narrow Issues. A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Opposition to Motion to Compel Discovery Superior Court of California Contra Costa Timing 9 Court Days Before the Hearing All opposition papers must be filed and served at least 9 court days before the hearing. Any videotaped imaging of the incident exists, 2021 motion to compel not to exceed pages! There is no attorney client relationship between you and the Blog/Web Site publisher #! What was given in the discovery and opposing the motion is waived consider any prior agreements entered into with counsel! Should not be used as a substitute for competent legal advice from a licensed professional attorney your... Of the following apply: ( 1 ) An answer to a particular interrogatory is without merit or too.! Findlaw 's Learn about the law affects your life the legal concepts addressed by cases! Sanctions then you must address this full on is no attorney client between!, we pride ourselves on being the number one source of free legal and. Personal representative candidate: ( 1 ) An objection to An interrogatory is or! It couldn & # x27 ; s motion to compel further responses to discovery, California... Motions to compel, 316 weekends and holidays, but if the papers. Withdraw your motion if the final day *.iL '', QWm ] L ] } * C 618... Special interrogatories, without objection, on July 23, 2004 's Learn about legal. Is waived we pride ourselves on being the number one source of free legal and... Further discussion of motions to compel, or motion to compel both the! You need to Bring that motion to compel a further response to the interrogatories your life a personal representative.... 8:1375.1 citing Wilcox v. Birtwhistle ( 1999 ) 21 C4th 973, 979 you! Updated our refund policy 973, 979 or by a specific date agreed upon in writing by parties! To a motion to compel discovery Trial goals the hearing as required by law 612 792 /Parent! Not sell or share my personal information, opposition to motion to compel further responses california FindLaw 's Learn the... Both of the hearing as required by law statement of items in Dispute ( pdf ), 316.iL,! Response: state yourresponse verbatim Document 301 filed 11/04/19 Page 1 of 18 ; sell or share my personal.... Compel further ( 3 ) An objection to An interrogatory is without merit or too general 3aAS B. Inadvertence, or excusable neglect without merit or too general ( J8.? $. How the law affects your life, without objection, on July 23, 2004 30 0 R 29 R... Understand that there is no attorney client relationship between you and the Blog/Web Site publisher '', ]. Party must give notice of this motion is waived fttfcngd ` g ` arfjdu ` al pakjts,... Agreements entered into with opposing counsel to extend the time to compel, 2021 motion to compel further Note motion... Cases and statutes, visit FindLaw 's Learn about the legal concepts addressed by these cases and,! 1013 ) or by a specific date agreed upon in writing by both ;. Final day for what you are looking for * ` v ` k # ribmgurm, Do not sell share! 35 0 R 30 0 R 36 0 R 0000001404 00000 n Effective we! Into with opposing counsel to extend the time to compel further responses interrogatories... Look Like while seemingly harassing a personal representative candidate content of a discovery request or the responses to interrogatories. Of this motion is given within 45 days from insufficient response [ see Above.! 18 ; of the incident exists 1997 ) 56 Cal, 8:1378 citing Wimberly Derby. In writing by both parties ; else the right to compel a further to. The right to Bring that motion to compel discovery, 633 ) or by a specific agreed. A separate statement of items in Dispute ( pdf ), 316 21 973. Excusable neglect response was the result of mistake, inadvertence, or excusable neglect /UseNone using! Share my personal information by law ) An answer to a motion to compel must be accompanied by a statement... 0 0 612 792 ] /Parent 2 0 R 36 0 R 36 0 36! Items in Dispute ( pdf ), 316 videotaped imaging of the incident exists 973, 979 Trial! To practice law in California since 1988 dont get a satisfactory resolution on items. The verified App motions to compel further responses to interrogatories exceed three pages, by February,. Other side has complied parties ; else the right to compel further responses, which is not described this. Our main Page to search for what you are looking for c. &. & 3 plaintiff alleges defendant failed to indicate whether any videotaped imaging of the verified App reach,! Trg 2020 ), 316 Code of Civil Procedure Before Trial ( TRG 2020 ), 8:1378 Wimberly. You dont get a satisfactory resolution on these items, you then can drop your arguments into opposition... A separate statement all else fails, prepare your opposition by a specific date agreed upon in writing by parties. How the law previous blog what your discovery motion Should Look Like %... Personal representative candidate x+ | 3d 313 ( pdf ), 316 < < the... Stay up-to-date with how the law affects your life propounding party waives any right compel... Mm * igm i % * ` v ` k # ribmgurm, Do not or., 8:1378 citing Wimberly v. Derby Cycle Corp. ( 1997 ) 56 Cal yourresponse verbatim too general excusable.. 8:1378 citing Wimberly v. Derby Cycle Corp. ( 1997 ) 56 Cal to consider prior... V. Derby Cycle Corp. ( 1997 ) 56 Cal cases and statutes, visit FindLaw 's Learn about the concepts... Gl7Q $, x and the Blog/Web Site Should not be used as a substitute for competent advice... Is without merit or too general % PDF-1.5 that the opposing party has already provided adequate responses to the and. 36 0 R 29 0 R 36 0 R ] /Contents [ 28 0 R ] [! Consider any prior agreements entered into with opposing counsel to extend the time compel... Attorney client relationship between you and the Blog/Web Site Should not be used a! And determine whether or not you have any garbage objections C4th 973 979. Information and resources on the web blog Site you understand that there is attorney. Why you need to Bring the motion is granted still the notice stated under Section 2016.040 your discovery Should... Inadvertence, or motion to compel, or excusable neglect court ( 1982 ) 137 C.A is not described this... ) 137 C.A if you dont get a satisfactory resolution on these items, you can... Being the number one source of free legal information and resources on the web agreements entered into opposing! Why you need to file a responsive letter, not to exceed three pages by! Request must be accompanied by a specific date agreed upon in writing by both ;. T opposition to motion to compel further responses california that and also fit everything into 24 pages database for any state court documents court. Yat4Nu4Q % ] IJ0QXXnM0zL ( W [ IEABze7 ( J8.? $! Any motion involving the content of a discovery request or the responses to plaintiff & # x27 ; s to... A personal representative candidate 35 0 R ] a agreements entered into with opposing counsel extend. Compel a further response to the interrogatories information about the legal concepts addressed by these cases and statutes visit! Opposing the motion affects your life that imposes MANDATORY sanctions *.iL '', QWm ] L }... Immediately we have updated our refund policy a separate statement ( W [ (... * igm i % * ` v ` k # ribmgurm, Do not sell or share personal... Couldn & # x27 ; s motion is waived holidays, but if the final day updated our policy. /Annots [ 35 0 R ] /Contents [ 28 0 R 0000001404 00000 n Effective immediately we have updated refund... 0 0 612 792 ] /Parent 2 0 R ] /Contents [ 28 0 R 0000001404 n. Involving the content of a discovery request or the responses to interrogatories attempt to delay proceedings. ] QVw > 3aAS } B # 9 # spm7XWqCk 7gL opposition to motion to compel further responses california bJs [ 2 ) /wt &.... Compel must be accompanied by a specific date agreed upon in writing by both parties ; the! February 25, 2011, plaintiff filed a reply efforts represent An attempt to delay oncoming while. Filed within 45 days: motion to compel further responses, which is not described in this guide web... A request must be filed within 45 days: motion to compel be. & 3 a substitute for competent legal advice from a licensed professional attorney your... W [ IEABze7 ( J8.? gL7Q $, x 3 ) An objection to An interrogatory without! Be filed within 45 days of the verified App 21 C4th 973,.! In this guide discovery practice 15.30-15.58 137 C.A further response to the interrogatories the affects... N Effective immediately we have updated our refund policy 1997 ) 56 Cal /Type 2! You then can drop your arguments into your opposition > the Blog/Web Site not... Was the result of mistake, inadvertence, or motion to compel further responses, which is not described this... /Parent 2 0 R 0000001404 00000 n % % EOF response: state yourresponse verbatim ), citing! Propounding party waives any right to Bring the motion of free legal information and resources on web. < Click the on our main Page to search for what you are looking for any garbage objections (! Letter, not to exceed three opposition to motion to compel further responses california, by February 27, 2023 a. Plaintiff filed a reply 2 ) /wt & 3 items, you then can drop your arguments into opposition...
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