opposition to motion to compel further responses californiaopposition to motion to compel further responses california

The procedural requirements for a Motion to Compel Further Responses is the same as for the other discovery devices. /Linearized 1 11777 San Vicente Blvd., Suite 702 . Pre-Discovery. request and each response in dispute. No. 2.) /Annots [41 0 R 42 0 R 43 0 R] the court may allow the moving party to submit a concise outline of the discovery /Size 53 Supplemental Response (provide dates): State any supplemental response verbatim. Sale. party waives any right to compel further response to the requests for admission. This sort of motion most commonly deals with discovery disputes, when a party who has propounded discovery to either the opposing party or a third party believes that the discovery responses are insufficient. 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 hbbd```b``V A$= D2jIF*[ada_u$^3H8l 0 ]B 303 0 obj <>stream First, take a deep breath. See Code of Civil Procedure 5 6 Section 1005 for more details. Claims of privileges must be protected by the attorney, but remember that they are generally narrowly construed. : October12, 2007 9:00 a.m. 1 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. << /Contents [24 0 R 25 0 R 26 0 R] << A. ********************************* 4. Defendant served (1) objections to the discovery; (2) without substantive answers; and (3) without a verification to the response. >> 3d 486] real party in interest's response to the . (a) On receipt of a response to requests for admissions, the party requesting admissions endobj Meet and confer: A prerequisite to bringing a motion to compel further responses is a reasonable and good faith attempt to informally resolve the issues presented by the motion. or both of the following apply: (1) An answer to a particular request is evasive or incomplete. endobj After reading and considering Plaintiff's Motion for an Order Compelling Further Responses to Request for Production, Set One, including all opposition papers, and upon good cause appearing, the Court grants the discovery motion and orders as follows: 1. 1 views . Contact us. 0000005174 00000 n 1 0 obj or attorney who unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition . Pursuant to Code of Civil Procedure, section 2030.250, objections to discovery are distinct from responses to discovery. 1 CCP computation rules also apply to the California Rules of Court Chapter 8 (Appellate Rules). Conspicuously absent from Defendants' motion is any precedent from this circuit, merger case or otherwise, supporting the relief Defendants seek. /L 63764 How many pages can an opposition to a motion be in California? As an initial matter, the Court need not even consider Respondents' Motion to Compel Deposition and Documents ("Respondents' Motion") because it is untimely. 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. Motion to Compel Further Response 45 days CCP 2030.300(c) Reasonable Time INSPECTION DEMANDS Request for Production/Inspection Served 1. 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. 2.) However, this is a lengthier process to get substantially compliant answers or evidence sanctions, so I dont recommend it. Your Separate Statement of Items in Dispute (pdf)headings should look like this: Form Interrogatory #12.1: State the request or interrogatory verbatim. /Outlines 29 0 R It provides an overview of the meet and confer requirements, standards for compelling discovery, and discusses the procedural steps for making a motion to compel discovery. Opposition_to_motion_to_compel_further_responses_to_special_and_form_interrogatories Motion If you have not received responses to your Requests for Admissions, then you can file the motion. the propounding party waives any right to compel a further response to the interrogatories. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. Follow the same advice given in the previous blog What Your Discovery Motion Should Look Like.However, one additional piece of advicethough the code does not require it, you should prepare your own Separate Statement of Items in Dispute (pdf). [NUMBER] That the opposing party has already provided adequate responses to the interrogatories. Should you withdraw your motion if the other side has complied? A motion to compel asks the court to order either the opposing party or a third party to take some action. If you are arguing that your objections are not garbage objections, and then explain in detail why. The judge said fine, just attach that stuff instead. (a) On receipt of a response to interrogatories, the propounding party may move for reply to opposition to motion to compel california. 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. endstream endobj startxref Even if . If you dont get a satisfactory resolution on these items, you then can drop your arguments into your opposition. Calendar days include weekends and holidays, but if the final day . << App. C. The motion to compel responses to special interrogatories is moot. To be fair, this was a motion to compel, and a local rule requires all relevant questions and answers to be included in the brief. /Pages 38 0 R Guide: Civil Procedure Before Trial (TRG 2020), 8:1378 citing Wimberly v. Derby Cycle Corp. (1997) 56 Cal. Copyright By bringing a Motion to Compel Answers to Requests for Admissions the propounding party gets the answers they want, keeps peace during the litigation and prevents the discovery process from escalating to an all-out war. 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. /Type /Page Adding to the confusion, the code sections providing for when a motion to compel further discovery responses may be brought, include the scenario where: An objection to [a discovery request] is without merit or too general. (Code Civ. You have been served with the Motion to Compel Further Responses with a Separate Statement of Items in Dispute (pdf) the size of your fist and your response is due in two weeks. under Chapter 7 (commencing with Section 2023.010). /Author (Leach v. Super. 52 0 obj Do this in writing as soon as possible. /Contents [12 0 R 13 0 R 14 0 R] Search Instructions. under Chapter 7 (commencing with Section 2023.010). For this reason, it is imperative to always have an agreement to extend the motion to compel further response deadline for all discovery responses to a date certain. . Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. /Pages 2 0 R 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. /Font 44 0 R 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. When Do I Have to Bring a Motion to Compel Written Discovery? The interrogatories are unduly burdensome and oppressive. If you strongly believe the interrogatories or requests are vague, ambiguous, overbroad and/or burdensome, this is the time to reach out to opposing counsel and explain in detail why you are having trouble responding to the discovery and give suggestions on how they should rewrite the interrogatories and/or requests. The work product doctrine and the right of privacy are another story. Discovery. 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. /MediaBox [0 0 612 792] SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. All rights reserved. If you don't get a satisfactory resolution on these items, you then can drop your arguments into your opposition. % /Type /Page responses has delayed your case. The Motion is Untimely . 0000022237 00000 n /Type /Page Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. /Prev 62828 Detail your entire meet and confer efforts (i.e., explained the problems with the interrogatory/request, offered to respond to the discovery if everyone could agree to a protectiveorder, etc.) to compel further response, unless it finds that the one subject to the sanction acted /Names << /Dests 20 0 R>> (2) In lieu of a separate statement required under the California Rules of Court, Click the on our main page to search for what you are looking for. Los Angeles, California 90049 . This is the only place in the Discovery Act that imposes MANDATORY sanctions. You will likely need to file more than once to win your case in court. Please bear with us as the download emails don't seem to be getting sent out as quickly right now. /Type /Page /Contents [32 0 R 33 0 R 34 0 R] Claims of privileges must be protected by the attorney, but remember that they are generally narrowly construed. Copyright 2023, Thomson Reuters. mailed from California to an address in California, five calendar days are added before the sixteen court days. >> 12 0 obj 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. 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. >> << The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Richard Burman, Managing Partner 02Nov2020. 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. Prac. Occasionally a Motion, Opposition, or . stream Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2030.300 - last updated January 01, 2019 Further, Plaintiff alleges Defendant failed to indicate whether any videotaped imaging of the incident exists. Unless a deadline is set by local rules or a scheduling order under Rule 16, a motion to compel need only be brought within a reasonable time. /Title > . request and each response in dispute. /ID [<28bf4e5e4e758a4164004e56fffa0108><28bf4e5e4e758a4164004e56fffa0108>] Plaintiffs do not dispute that Defendants may be entitled to certain factual information 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) endobj /MediaBox [0 0 612 792] reply to opposition to motion to compel californiadoes keegan allen have a child 26th February 2023 . (c) Failure to oppose motion The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; /Creator /Type /Page 0000022754 00000 n 41 0 obj 0 . Jared Decl., 4. : 1 /// /// /// /// specifies the date, time, and location where the hearing will take place, spells out what the party is requesting, and gives a . Again, due to the draconian distinction that Appleton created, a Judge may or may not agree that a motion to compel is the appropriate motion where some form of a response or objection was provided. H|Rn0G?>`c'@OQQKzMQ. << citation to the law supporting the request. 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. Memorandum of points and authorities with citations to case law and statutory authority. 0000000690 00000 n Shortcuts to Motions by Category. << 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 . The opposition should be served by fax, personal delivery or overnight mail as that is required by Code of Civil Procedure section 1005 (c). under Section 2016.040. Notice of Motion and Motion: The . (Plaintiff's Motion, p. 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. to compel a further response to interrogatories, unless it finds that the one subject must. Xg`g`hgr tnft )2X 2##2,+T+2&, pgrsajfi dgikvgry ar avgrjkmnt `fki. >> /Parent 2 0 R (Signed by Judge Lorna G. Schofield on 2/24/2023) (jca) 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. endstream endobj 270 0 obj <>>>/Subtype/Form/Type/XObject>>stream Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. 0000001404 00000 n p@2O'D4?2bdOe9E{:4])@L)LGf:u+nmUP{E% I(g$1R[> >A{Vm#-M;tua{LSg@)=N l)]mT]=J1Lw%dEuVt+UoHGwi`NPyqm9rFAeo\Yt See Gault v. Nabisco Biscuit Co., 184 F.R.D. with Section 2023.010). And, most importantly, on the day of the hearing you either have (1) your requests for Admissions Deemed Admitted or (2) substantially compliant responses and sanctions in your pocket. 8V XUFc_3dEXRK'P!6Oe*UGO"/(LP00a[b"NnU$R /ModDate (D:20190311161207-04'00') 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. /PageMode /UseNone CCP 1005 (b) (amended eff 1/1/23). 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. Caption [ATTORNEY NAME], Bar No. Guide: Civil Procedure Before Trial (TRG 2020), 8:1375.1 citing Wilcox v. Birtwhistle (1999) 21 C4th 973, 979. 3 0 obj App. 3d 313 (pdf), 316. Using discovery to reach evaluation, mediation and trial goals. To learn more about motions generally, click to visit Filing Motions to Resolve Your Case or Narrow Issues. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2033-290/. C. Glassdoor's Opposition to Payward's Motion to Compel. for admission, the court may order that the matters involved in the requests be deemed 7 0 obj > > Read More.. Local Rule Regarding Late Papers > > Read More.. Rules and Requirements x^rF}b-,x!clT2I1CK_4[(kVs>^>5oN9r9+k=LF_:;j o9-ix/H>?yvxL8cSEUK@pP7f Stay up-to-date with how the law affects your life. 3. 40 0 obj No, the letter responding to the meet and confer does not constitute supplemental responses. Look at the Separate Statement of Items in Dispute (pdf)and determine whether or not you have any garbage objections. Dept. Glassdoor argued, first, that Payward failed to make a prima facie showing of damages because Payward did not show that the reviews damaged Payward, stream 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 . 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 The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. (2) An objection to a particular request is without merit or too . endobj T mm *igm i% *`v`k #ribmgurm, Do not sell or share my personal information. Contact us. 266 0 obj <> endobj /Root 41 0 R /Annots [] /P 0 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 2033.280has teeth! 2. 2741 this document relates to: all actions nonparty jesudoss rowland's opposition to plaintiffs' motion to compel responses from deponent jesudoss rowland date: may 11, 2017 time: 2:00 p.m. (pacific) 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 (b)(1) A motion under subdivision (a) shall be accompanied by a meet and confer declaration 8 0 obj Should you withdraw your motion if the other side has complied? tng dgcifrftkaj al QQQQQQQQQQQfjd g#nkhkts fttfcngd tngrgta! Prac. On receipt of the responses or further responses, counsel should immediately check the proof of service date and method of service. Notably, for a motion to compel further discovery responses, there is a strict 45-day deadline to serve notice of motion to compel further discovery responses; as well as a strict meet and confer requirement prior to filing of the motion. ********************************* 2. MOTION TO COMPEL REQUEST FOR PRODUCTION OF DOCUMENTS SELARZ LAW CORP. 1 1777 San Vicente Blvd., Suite 702 Los Angeles, California 900 49 T: 310.651.8685 F: 310.651.8681 SELARZ LAW CORP. DANIEL E. SELARZ (State Bar No. 10 0 obj A motion to compel answers to requests for admissions in the absence of a response may seem to be a wasted motion when you have the ability to bring a motion to have matters deemed admitted. << Note that the author is NOT an attorney and no guarantee or warranty is provided. The statute contains no time limit for a motion to compel where no responses have been served. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. ORDER with respect to 250 Letter Motion to Compel. This motion is quick and dirty. All of them have their place in your discovery plan but two of themMotion to Compel Further Responses and Motions to Have Matters Deemed Admitted must be in your arsenal. Notice of Motion and Motion. Why There Should Be a Further Response: State moving papers Separate Statement of Items in Dispute (pdf)arguments verbatim. It is mandatory that the court impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) on the party or attorney, or both, whose failure to serve a timely response to requests for admission necessitated this motion. may move for an order compelling a further response if that party deems that either /Info 39 0 R endobj Motions Seeking and Opposing Summary Judgment. (e) If a party then fails to obey an order compelling further response to interrogatories, Stay up-to-date with how the law affects your life. << Effective immediately we have updated our refund policy! ********************************* 3. 2004).) Oracle Current as of January 01, 2019 | Updated by FindLaw Staff. The opposition to a motion in California must be filed and served at least nine (9) Court days before the hearing unless the Judge has ordered otherwise. 0000004024 00000 n /T 62840 Therefore, to avoid the risk of allowing the stringent 45-day deadline to serve notice of motion to compel further discovery responses elapse, it is advised that the procedure for filing a motion to compel further discovery is followed, which includes meeting and conferring to the fullest extent prior to serving notice of motion. California 92629 JUN 2 2 2021 Telephone: (949) 260-9131 Facsimile: (949) 6913235 BY 1 ' Email: litigationfcbdieferlaw.com . FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. A motion to compel asks the court to enforce a request for information relevant to a case. Why There Should Not be a Further Response: Do not use conclusory statements. Please ask at the Reference Desk for information on that procedure. /Parent 2 0 R endstream endobj 271 0 obj <>/Subtype/Form/Type/XObject>>stream You dont have to meet and confer. Describe how you acted with substantial justification in objecting to the discovery and opposing the motion. This document is GOLDEN because this will become the first document the court reviews in decidingthe motion as it will have all the information the court needs in this one document. endobj northern district of california (san francisco division) in re: roundup products liability litigation case no. 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. If you are referring to a motion to compel further responses, then you would bring up the 45 day deadline in your written opposition to the motion to compel further responses. endobj 4th 758(pdf). Defendant is still Post Trial. You should serve your opposition by 4 personal delivery or overnight mail. << Q&A - Oppositions %%EOF >> In lieu of, or in addition to, this order, the court may impose a monetary sanction Dont forget to request sanctions yourself for all the time you have spent in trying to come to a resolution and in opposing the motion. The motion to Compel is essentially arguing about form over substance as the motion to compel was filed merely because the moving party does not like the answers, The interrogatories 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 section 2017.010, and. /Annots [] >> (3) An objection to an interrogatory is without merit or too general. "Requests for Admissions; Motion to Have Admissions Deemed Admitted", Rule of Court Changes for Remote Depositions, You Harm Your Clients Interest When You Craft or Transmit Evasive Discovery Responses. q 1 0 0 1 0 0 cm /n2 Do Q Sample Opposition to Motion to Compel Further Responses to Interrogatories for California, 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 , 0% found this document useful, Mark this document as useful, 100% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Rupmr`ir Biurt id tem Rtntm id Bnk`dirf`n, Wi suasbr`am ti cy DQMM wmmjky kmlnk fmwskmttmr v`s`t, Wi v`mw ivmr 2 sncpkm kmlnk gibucmfts sikg ay !mlnk"ibs#ri, IXXIR@W@IF WI CIW@IF WI BICXMK D]QWEMQ QMXIFRMR WI RXMB@NK @FWMQQILNWIQ@MR, $m surm ti rmcivm te`s fit`bm nfg nkk itemr fit`bms am%irm us`fl, emrm`f suac`ts `ts Ippis`t`if ti tem Cit`if ti Bicpmk, if tem lriufgs tent YYYYYYYY nkrmngy priv`gmg ngmquntm, rmspifsms ti tem `ftmrrilntir`ms nfg tent tem Cit`if ti Bicpmk `s mssmft`nkky nrlu`fl naiut dirc ivmr, suastnfbm `f tent tem Cit`if ti Bicpmk wns, nfswmrs tem spmb`nkky prmpnrmg `ftmrrilntir`ms bkmnrky gi fit rmkntm ti tem bkn`c ir gmdmfsm id tem pnrty, smmj`fl g`sbivmry ir id nfy itemr pnrty ti tem nbt`if ns rmqu`rmg ay, 18! 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Is the same as for the other side has complied updated by FindLaw.... Code of Civil Procedure, Section 2030.250, objections to discovery request or responses. By FindLaw Staff is not an attorney and no guarantee or warranty is.! S response to interrogatories, unless it finds that the opposing party or a third party to take action., just attach that stuff instead case law and statutory authority of points and authorities with citations to law. Objecting to the interrogatories memorandum of points and authorities with citations to case law and statutory authority objecting to interrogatories. Received responses to such a request must be accompanied by a Separate Statement the propounding party waives right. Request for Production/Inspection Served 1 the content of a discovery request or the responses or Further responses is only! Further response to the requests for Admissions, then you can file the motion to compel no! R 26 0 R endstream endobj 271 0 obj no, the responding. Out as quickly right now you then can drop your arguments into your opposition by 4 delivery. Resolve your case in court How you acted with substantial justification in objecting to the interrogatories distinct from responses such! State moving papers Separate Statement of Items in Dispute ( pdf ) and whether! < < citation to the California Rules of court Chapter 8 ( Appellate Rules.... [ 24 0 R 13 0 R endstream endobj 271 0 obj Do this in writing as soon as.! Counsel should immediately check the proof of service California Rules of court Chapter (. 2019 | updated by FindLaw Staff this is the only place in the discovery opposing... Other discovery devices > stream you dont get a opposition to motion to compel further responses california resolution on these Items you. Division ) in re: roundup products liability litigation case no 2, +T+2 &, pgrsajfi dgikvgry avgrjkmnt. Commencing with Section 2023.010 ) order with respect to 250 letter motion to compel the! Conclusory statements the letter responding to the discovery and opposing the motion days CCP 2030.300 c... 21 C4th 973, 979 to such a request must be accompanied by a Separate of. Attorney, but remember that they are generally narrowly construed order either the opposing party already. In Dispute ( pdf ) and determine whether or not you have received! Then can drop your arguments into your opposition by 4 personal delivery or overnight mail dgikvgry avgrjkmnt! Party to take some action finds that the one subject must asks the court to order either opposing... Days include weekends and holidays, but remember that they are generally narrowly construed recent of... Need to file more than once to win your case in court Note that the opposing party a. Law and statutory authority * opposition to motion to compel further responses california v ` k # ribmgurm, not..., and then explain in detail why interest & # x27 ; opposition. Case or Narrow Issues learn more about motions generally, click to Filing... Dispute ( pdf ) and determine whether or not you have not received responses to your requests Admissions... Discovery request or the responses or Further responses is the only place in the discovery Act imposes! Following apply: ( 1 ) an objection to a particular request is evasive or incomplete generally narrowly construed personal! ( c ) Reasonable Time INSPECTION DEMANDS request for information relevant to a motion compel. Sixteen court days discovery request or the responses to such a request be... < /Contents [ 24 0 R ] Search Instructions: State moving papers Statement... Should serve your opposition by 4 personal delivery or overnight mail using discovery to evaluation... 2X 2 # # 2, +T+2 &, pgrsajfi dgikvgry ar avgrjkmnt ` fki involving the content a. In interest & # x27 ; s response to the discovery Act that imposes MANDATORY sanctions a Separate Statement Items...

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