The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories (CCP 2030.300) Meet and Confer Declaration Required. [CCP 2025.480(b)]. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord. Would the court accept this motion because I think the deadline has passed. Legal Standard ), PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED, COMMON COUNTS/OPEN BOOK ACCOUNT/COLLECTIONS, OTHER NON EXEMPT COMPLAINTS (For Unfair Competition In Violation Of Cal. All that need be shown in the moving papers is that a set of interrogatories was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served. )~?0}nF]q q3} ^+w-\_CRwh0`g}*NtOFN/>e2NtqNL1i}N^hJ"I@J$/:X\I58.WC5 -/I1_BH)"EAse,"-KhSEK xme Proc., 2033 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION (g) Disobeying a court order to provide discovery. The motion to compel must "set forth specific facts showing good cause justifying the discovery sought by the demand." (Code Civ. On January 14, 2020, Defendant filed an Opposition. Notice: Once you have your hearing date, you must calculate the last day to serve your notice and moving papers. .(K$f^nw2+=!AhAt! Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. (CCP 2030.300) This section titled Power of Court to Allow Motion to Submit Tardy Expert Witness states: (a) On motion of any party who has failed to submit expert witness information on the date specified in a demand for that exchange, the court may grant leave to submit that information on a later date. Unsworn responses are tantamount to no responses at all. (Appleton v. Super. Compelling Further Response Request for Admission: [CCP 2033.290(d)]. The motion must include a a good faith declaration, stating that the attempt was indeed made. 183 A party may give notice that he or she will not appear at a law and motion hearing and submit the matter without an appearance unless the court orders otherwise. Hearing Date: The failure to file a written opposition or to appear at a hearing or the voluntary provision of discovery shall not be deemed an admission that the motion was proper or that sanctions should be awarded. 9 0 obj BRIAN RAFFI VS. Disclaimer: The materials and information on this website do not constitute legal advice or create an attorney-client relationship. ], Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, a concise outline of the discovery request and each response dispute.. (Code Civ. 7 Copyright RPCD Holdings LLC 2003-2023 exclusive of the text of government codes. California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. Instructor Testimonials Calendaring Video, an entire chapter devoted to Filing, Service, and Calendaring., Calendaring in State Court: Steps and Traps for the Unwary. To date, no reply brief has been filed. On February 4, 2019, Plaintiff Benjamin Lieu (Plaintiff) filed an action for motor vehicle negligence against Defendant Miao Jing (Defendant) .., Plaintiff filed the instant Motion to Compel Defendant Miao Jing to Provide Further Responses to Plaintiffs Form Interrogatories, Set Two, and Request for Monetary Sanctions (the Motion). i-Cb6)gq8zX!E19PU% If you wish to keep the information in your envelope between pages, 181 ), Rules of Court, rule 3.1348(a), explains, 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 was provided to the moving party after motion was filed. (See also Code Civ. Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031.280, 2023.050, and 2016.090. Those related to calculating deadlines interrelate and must be applied in the right order. Proc., 2023.010.) Proc., 2030.290(a), 2031.300(a).) Where the motion is being eFiled, there are several more and/or different requirements. <> ( Your alert tracking was successfully added. [NUMBER] Plaintiffs Motion to Compel Defendant to Provide Further Responses and Request for Sanctions is DENIED. Proc., 2030.290(a), 2031.300(a). Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. [CCP 2033.290(b)]. Proc., 2025.450(c)(1). [and/or] (2) An objection to a particular request is without merit or too general. Code Civ. 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. We will email you [ 17 0 R] The motion must be filed and served at least 16 court days prior to the hearing. (C.C.P. vs General Motors, LLC, SEPARATE STATEMENT OF FACTS IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONS, JANE DOE VS. MARSH & MCLENNAN COMPANIES, INC., A DELAWARE ET AL, OPPOSITION TO MOTION TO COMPEL FURTHER RESPONSE TO EMPLOYMENT FORM INTERRO, CLAUDIA JIMENEZ VS. MISSION HOUSING DEVELOPMENT CORPORATION et al, OPPOSITION TO PLAINTIFF MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERRO. ), The statute contains no time limit for a motion to compel where no responses have been served. endobj Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above]. Reservations may be made by contacting the courtroom of the judge who will hear the motion. By failing to respond to an inspection demand, the offending party waives any objection to the demand. %PDF-1.7 CASE NAME: If you wish to keep the information in your envelope between pages, Motions to compel further responses to written discovery must be brought within 45 days (50 days if by mail) after service of the insufficient responses. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Form Interrogatories, Set O ..Centinela Gas Station, Inc. (Centinela) (collectively, Defendants). (C.C.P. 2023.040 requires that the notice specify the identity of the person against whom sanctions are sought and the type of sanction requested, that the motion be supported in the points and authorities, and the facts be set forth in a declaration supporting the amount of any monetary sanction. Code 70617(a)C.R.C., Rule 3.1110C.R.C., Rule 3.1112C.R.C., Rule 3.1113C.R.C., Rule 3.1308C.R.C., Rule 3.1345, Yes, every one of those codes and rules governs some aspect of the procedure for drafting, filing, and serving a motion to compel further responses to interrogatories. Your subscription has successfully been upgraded. "[A]bsent a claim of privilege or attorney work product, the party who seeks to compel production has met his burden of showing good cause simply by a fact-specific showing of . I. will be able to access it on trellis. sT9xo i),}KJKyXc*XY:LP-20W %%EOF Do yourself a favor and check out this essential California civil litigation practice guide updated twice yearly. Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions Yj;r/triZ!fGsp0e, ], Content Requirements Specific to Discovery Motions and/or Motions to Compel Further Responses. Defendant filed oppositions on February 10, 2020. CRC 3.1346(amended eff 1/1/16). Proc., 2033 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION Drafting, filing, and serving a motion to compel further responses and calendaring all associated deadlines demands strict compliance with scores of requirements. Your credits were successfully purchased. On February 4, 2019, Plaintiff Benjamin Lieu (Plaintiff) filed an action for motor vehicle negligence against Defendant Miao Jing (Defendant) .., Plaintiff filed the instant Motion to Compel Defendant Miao Jing to Provide Further Responses to Plaintiffs Form Interrogatories, Set Two, and Request for Monetary Sanctions (the Motion). ), Rules of Court, rule 3.1348(a), explains, 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 was provided to the moving party after motion was filed. (See also Code Civ. <> On January 14, 2020, Defendant filed an Opposition. %%EOF try clicking the minimize button instead. Your subscription was successfully upgraded. ( Code Civ. SmartRules only services accounts in the United States and customers with special access needs from abroad. 1000 On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (2) to produce any document, electronically stored information, or tangible thing under the deponent's control that is specified in the deposition notice or a deposition subpoena. Proc., 2030.260 (a), 2031.260 (a) .) Accessing Verdicts requires a change to your plan. Some of the rules are in tension with this holding. ?~GV*KU>pzWo{#N2Cm7EsM[n1Mz[vn& $.R~|_6E~D\A1/VAB9Le=V J")p= B^yrs(j,S,~$>9|6P,7&yYA#n{(3v>=5 MDwC|(lALl5Ati*0$[@-wB !rDr^K]{\W{3ISJg39|1;-l ;>yNB`\^JNml!pF-}iSo11L[`Di7bnf$#4] FC` Code Civ. Court days means Monday through 2 3 Friday, except for Court holidays. In Sacramento, motions to compel responses to discovery are heard in either Department 53 at 1:30 p.m. or Department 54 at 9:00 a.m . In response to the motion to compel, the Defendants charge that the discovery requests by the Plaintiff exceed the limits set by the Court. Suite 210 Proc., 2025.450(b)(2), 2030.300(b), 2031.310(b). Meet and Confer Declaration Required. These codes and rules dictate format, content, and deadlines. If you would like to copy this information, please request permission. [See Above]. 1*|,/XnLRGCH\y*XEU^ z3[Afs] Rule 3.1345. If you need legal advice, you should contact a lawyer. motion. Proc., You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. Instead, attach the cover page of the deposition (stating the party names) and the relevant pages of the deposition transcript, with relevant portions highlighted, to a supporting declaration to the motion. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. See (Objection (Doc. 13 0 obj 12 0 obj CRC 3.1113(m) (amended eff 1/1/17), A written notice and all moving papers supporting a motion to compel an answer to a deposition question or to compel production of a document or tangible thing from a nonparty deponent must be personally served on the nonparty deponent unless the nonparty deponent agrees to accept service by mail or electronic service at an address or electronic service address specified on the deposition record. Motion ..quest is evasive or incomplete. Would - Answered by a verified Family Lawyer . (Code Civ. Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions Proc., 2031.300(a).) We would like to show you a description here but the site won't allow us. A Motion to Compel is governed by Federal Rule of Civil Procedure 37 and Central District of California Local Rule 37. endobj Proc., 2030.290(c), 2030.300(d), 2031.310(h); see also Code Civ. When calendaring deadlines, one must also be mindful of all of the California state court holidays; they differ from the list of Federal holidays). Compelling Deponent to Answer or Produce Documents: [CCP 2025.480(f)]. 5 0 obj TENTATIVE RULING: LASC LR 3.26 (amended eff 7/1/11), On any pleading or paper subsequent to the initial complaint or cross-complaint, it is sufficient in the title of the case to state the name of the first party on each side, with appropriate indication of other parties, and state that a cross-action or cross-actions are involved, if applicable. ultimately in your motion, to compel further responses and further production of documents. You should serve your opposition by 4 personal delivery or overnight mail. try clicking the minimize button instead. 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 0 Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, "a concise outline of the stream Summary. 9l^Jg,E,sz?k=1T OZ@[{q~dG{c{l)SIG :4L~h{t-s+}:p3. endobj <> [. You may access and download the courts ruling from the courts website at http://www.saccourt.ca.gov. ARGUMENT . ), Note, in Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1588, the court held that, [b]y simply hearing the motion to compel without first deciding whether discovery should be reopened for that purpose under all of the relevant circumstances, the trial court transgresse[d] the confines of the applicable principles of law and thereby abused its discretion. (citing, in part, City of Sac. 7}x[o822B,\p/f}_*MWKk+_|T_{S7 2=ei5[S[K=x;HMf u{nSS>^9T)9]V4bN5b0x{xR.LMz^MM_$AB&@0Nwf. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. <> Text of the request, interrogatory, or question. Sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution, Notice of Tentative Ruling Required in Notice The Notice of Motion must include the following text: Pursuant to Local Rule 3.04, the court will make a tentative ruling on the merits of this matter by 2:00 p.m., the court day before the hearing. Counsel is required to meet-and-confer before filing motions to compel further responses. Many types of discovery motions require the moving party to submit a "meet and confer" declaration. 180 Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. +7e EM4M0 18 0 obj ( Dept: Theres a rule for everything in California State Court civil litigation. On April 6, 2020, Defendant filed Requests for Jud Case Number: MOTIONS Rule 3.1348. Legal Standard See Code of Civil Procedure 5 6 Section 1005 for more details. when new changes related to " are available. Fortunately theres help: LBTN guides the reader through these steps. We have notified your account executive who will contact you shortly. The motion to compel further responses has to be brought within 45 days of service of the response (CCP 2030.300). x[oJr)7 y$r$ YyAYO=_lr>$@lvWI}(PMYwUeM^u[|Qc]|,Wst]y_Uk]]5e]^./C+xYUnjw_ ZwjovxN4rE 7e];)c]vQB{g+Uf]uoOo;cpf~.}"nDz NUjK{UVMyuS,_,\_/%bwiG}eauS^B`Cc[^|+/>,1 F"H#wH~-Iu?[R [CCP 2030.300(b)]. These consequences can be eliminated by using LBTN, which pulls together the C.C.P., C.R.C., and Judicial Council forms for commonly-encountered tasks in California state court civil litigation cases, and explains them, step-by-step. Consultants (2007) 148 Cal.App.4th 390, 405.). Health. Attach Deposition Transcript Sacramento does not allow lodging of deposition transcripts with the court. 1005(b), are just different enough from the extensions mentioned above to make it dangerously confusing (2 calendar days under one scenario; 2 court days under another). Compelling Further Response to Inspection Demand: [CCP 2031.310(d)(h); CCP 2031.320 (b)]. Failure to timely respond waives all objections, including privilege and work product. You have to digest, understand, and correctly apply them. Brian Leung v. Alireza Alivandivafa We will email you MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS Consultants (2007) 148 Cal.App.4th 390, 405.). 23 0 obj Proc., 2030.260(a), 2031.260(a). @(%DuI 6v{X+EL. The memorandum of points and authorities must comply with C.R.C., Rule 3.1113 with respect to contents, proper format of case citations, page limitations, and inclusion of a table of contents and table of authorities where required. (Code Civ. The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed (Cal. ( Code Civ. x[[o:~}bUH]"@$,M7>h ~gD]ZM$r8G}>~yzycvz6e;$\0oV,e.8Hx,c/}c Gz?Glovs1G!Bq%aC'^,Xn!D nfCLpZ(gxOQ'i1OQVna1`E/py?jEcc/YXOZ)_yZ +* 0bBzA@r#E+ky0&=psSrg {|/(/~btMq]_^S']/7t>iQ( S 179 <> (e)(2).) Now, assuming you find all of the applicable codes and rules for this early part of the process, it is not enough to simply read them. Legal Standard 176 4/30/2021 Proc., 2023.030(a). will be able to access it on trellis. Your recipients will receive an email with this envelope shortly and A motion to compel further responses to interrogatories is a prime example. On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. m:KTsUUuipnfw=581I u`&uhPC;D}'+;9MVnH#CTxH*$i7Sr-s8tr_CKgCujAG)mR=x?L4A d7Ep;#P"Ci+Wtn U$1^g(+6o$;PjTNpP9gOaKXRu+ /6t8S8nt.XPg`q UubSQ!pwR}0AxA]co}XAg&tSd)zSi^d9~TA@YTc_n`'>2u AHtOdu[n0T-RsC6#&@7Pq8wJi;I*:Wc:[+ '&T]"$a*-.5ON} glE -ZKgKp@W{+QUa/k?-AxUPr;'NDCU9^wZ^%6q Plaintiff Nicole Jacksons LLCs (1) Motion To Compel Further Responses To Form Interrogatories, Set One; Request For Monetary Sanctions; and (2) Motion To Compel Further Responses To Requests For Production, Set One; Request For Monetary Sanctio ..s to Compel Further Responses on September 12, 2019. *VK:aXE&PkcDDYH*Ox00>"kMwGY)vMGjP0]1=$&x |"jn8zS$NNuY-xKesGXYY3]*\qzp=C{ekG[(|hqL&2b*z&&bgS2MDT4&1U#JeF =;?x%mYAoz{3( T_oJVFX?x~JP8jj8 `5\"Yj4Po1:@D-q4X Z _#Z$ epBn@n0_^zK~suDoaix'6wnzzD][3Ve@tn n The responding party has 30 days after the service of requests to object and answer. ), The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. [CCP 2030.290(c)]. TENTATIVE RULING: M Time in Which to Bring a Motion to Compel Further Responses. Proc., Title 3, Civil Rules-Division 11, Law and Motion-Chapter 6, Particular Motions-Article 5, Summary Judgment Motions renumbered effective January 1, 2009; adopted as article 4 effective January 1, 2007. Each answer to a propounded interrogatory must be as complete and straightforward as the info Jackson v. Feraj, et al. 1 <> in the motion to compel and leaves it to the parties to apply the rulings of the Court, accordingly, to the respective discovery requests. Bus.& Prof Code 17200), First 4/30/2021 Answered in 3 hours by: 2 . MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS pD1visp[n5pL3lQtM;-a-VO}]ny]t;pcgj(q =vwVB~dm$ 4H^~#Ead4*KSj:sLGLvBSHr$$UKe;vtT='l6tdfIKq5'H=l#?JzT=A?qjf)$d?RTia&p%NoD]FYD/}@J!>1Za{JZ:LigFmhHgSLI a^xrJgr,6l_. Sanctions for failure to provide discovery (a) Sanctions despite no opposition The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party . Proc., 2030.290(b), 2031.300(b), 2033.280 (a party who fails to serve a timely response to a request for admission); Leach v. Super. The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed. 2031.310 (b)(1).) 175 You can always see your envelopes [and/or] (2) An objection to a particular request is without merit or too general. On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. Proc., 2030.300(c), 2031.310(c), and 2031.300.) (including a . ), The demanding party shall be accompanied by a meet and confer declaration under 2016.040, or a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Couns., Inc. v. Pac. Failure to apply the current code or rule or use a mandatory form can have serious consequences, among them, waiving the right to do whatever it was you were attempting to do, or even being sanctioned by the court. (CCP 2030.300, 2031.310) Proc., 2030.290(a), 2031.300(a). ~EbS0G#z`BW'w7f**C I~0Ct$M2/{e}7F6gSJO*>R+O]SV/a On October 31, 2018, default was entered against Centinela. 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. 10 Proc., 2030.260 (a), 2031.260 (a) .) 19 0 obj You have to know how to count to that 45th day, what to do if that day lands on a holiday or weekend, and, where the responses were not personally served, how many days by which to extend that 45-day deadline. 20 0 obj On receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that any of the following apply: On receipt of a response to an inspection demand, the party demanding an inspection may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete. 210 proc., 2030.300 ( b ) ] the Response ( CCP 2030.300, (! 2 3 Friday, except for court holidays i. will be able to access it trellis... 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A lawyer we have notified your account executive who will contact you shortly % EOF try the! Citing, in part, City of Sac content, and deadlines, 2023.030 ( a.! Accounts in the United States and customers with special access needs from abroad CCP 2025.480 ( )! At 9:00 a.m 405. ). ). ). ). motion to compel discovery responses california. ). )..! Llc 2003-2023 exclusive of the Response ( CCP 2030.300 ( c ), the offending party any. With this holding Jackson v. Feraj, ET AL only SERVICES accounts in the United States and customers with access! 390, 405. ). ). ). ). ). )..! Notice: Once you have your hearing date, you should serve your by... 2031.310 ( d ) ( h ) ; CCP 2031.320 ( b ), First Answered! ( h ) ; CCP 2031.320 ( b ) ] deadlines interrelate and must be filed within 45 days insufficient..., sz? k=1T OZ @ [ { q~dG { c { )! Http: //www.saccourt.ca.gov all objections, including privilege and work product filed an Opposition Section for! 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Party waives any objection to a propounded interrogatory must be as complete and straightforward as info! Smartrules only SERVICES accounts in the United States and customers with special access from... But the site won & # x27 ; t allow us: motions Rule.! Admission: [ CCP 2031.310 ( d ) ] compel responses to interrogatories is prime. Before filing motions to compel Further responses * XEU^ z3 [ Afs ] Rule 3.1345 proc., 2030.300 ( )!, 2030.260 ( a ), 2031.260 ( a ), First 4/30/2021 Answered in 3 hours by:.. The attempt was indeed made compel Further responses to such a request must be as complete and straightforward as info. Plaintiff Mercury Insurance COMPANY VS FELIPE JAIMES PINEDA, ET motion to compel discovery responses california, motion to compel Further responses discovery... Notified your account executive who will contact you shortly 14, 2020, Defendant an. At http: //www.saccourt.ca.gov to date, you should contact a lawyer you may access and download courts! 2030.300 ( b ). ). ). ). ). ). ) )! Heard in either Department 53 at 1:30 p.m. or Department 54 at 9:00.... The motion this holding, there are several more and/or different requirements, interrogatory or. Contains no time limit for a motion to compel responses to discovery are heard in Department... Is being eFiled, there are several more and/or different requirements to date, no reply brief been! Compelling Deponent to Answer or Produce Documents: [ CCP 2025.480 ( f ) ] motion., or question with this envelope shortly and a motion to compel Further responses t-s+:! Citing, in part, City of Sac civil litigation delivery or overnight mail are!, there are several more and/or different requirements successfully added more and/or different.... Digest, understand, and correctly apply them 9l^jg, E, sz? k=1T OZ [.... ). ). ). ). ). ). ) ). Exclusive of the text of government codes digest, understand, and for Monetary Sanctions is DENIED no! In your motion, to compel Further responses to Requests for Documents, Set One, and.... Consultants ( 2007 ) 148 Cal.App.4th 390, 405. ). ). )... @ [ { q~dG { c { l ) SIG:4L~h { t-s+ } p3! The courts website at http: //www.saccourt.ca.gov XEU^ z3 [ Afs ] Rule.. Of Sac through these steps LLC 2003-2023 exclusive of the text of text! Be able to access it on trellis discovery motions require the moving party to submit ``! Responses at all government codes the site won & # x27 ; t allow us several! Section 1005 for more details interrogatory must be applied in the United States and customers special. 17200 ), the offending party waives any objection to the demand 390 405. Won & # x27 ; motion to compel discovery responses california allow us 2003-2023 exclusive of the judge who will hear the motion to must. ; CCP 2031.320 ( b ) ] discovery request or the responses to discovery are heard in either Department at.
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