Construction Products Liability Electronic Discovery

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All Answers Remain the Same

A party should use supplemental interrogatories and demands in an efficient and effective manner. They should be sent at least once a year and no later then 90 days before trial. The responses you obtain should direct you...more

The Document From Hell--AKA The "Privilege Log"

In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. ยง2031.220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P....more

Quoting Shakespeare

Last spring I had the pleasure of taking a tour of the Royal Globe Theatre in London, England. On display there was a plaque titled "Quoting Shakespeare." It brought a smile to my face when I read the passage as I realized...more

INSPECTION DEMANDS-What is a Reasonable Inquiry?

To determine whether or not a responding party has made a reasonable inquiry, you must determine where the responding party searched (what efforts were made), who did they talk to (did they make an inquiry to their legal...more

INSPECTION DEMANDS--What is a "Diligent Search"?

Have you ever received a response to requests for production of documents that says: After a diligent search and a reasonable inquiry has been made in an effort to comply with this Request, there are no documents within...more

GIve Me All Your Documents!

I recently reviewed a case management order in a complex construction case venued in Southern California. The order required all parties to produce: Any and all relevant non-privileged and non-protected documents...more

Requests for Admissions--THE MOTIONS

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. All of them have their place in your discovery plan but two of...more

Answering Requests for Admissions--Beware of the Traps

Answering Requests for Admissions is very similar to answering interrogatories-you have an obligation to respond in good faith and you have to be careful about your garbage objections. However, the code makes it clear that...more

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