Electronic Discovery, Construction Law

Construction Attorneys--You Can Now Check the Box!!

by Katherine Gallo, Esq. on 10/30/2012

I am pleased to report that the California Judicial Council has approved for use Form Interrogatories--Construction Litigation (form DISC-005). The approved form will be on the Judicial Council website at...more

All Answers Remain the Same

by Katherine Gallo, Esq. on 8/21/2012

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

YOU NEED TO FILE A MOTION FOR PROTECTIVE ORDER!!

by Katherine Gallo, Esq. on 6/7/2012

Over lunch last week, a local attorney was complaining to me about his case that is going to trial in July. On the last day to serve written discovery, Plaintiff counsel had served each of his five clients, on behalf of each...more

Save Time, Money & Angst -- MEET and CONFER

by Katherine Gallo, Esq. on 3/2/2012

The purpose of the “meet and confer” requirements set forth in C.C.P. §§ 25.450(b)(2)), 2025.480, 2030.300(b), 2031.310(b), 2032.250 and 2033.290 was for the lawyers to revisit their position, in good faith discuss a...more

Am I Naïve to Think Something Should Be Done?

by Katherine Gallo, Esq. on 2/27/2012

What do you do when you are being out muscled by a party who has deep pockets and a lawyer who's intent is to abuse the discovery process and run up his bills. ANSWER--GET THE COURT INVOLVED!!...more

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

by Katherine Gallo, Esq. on 1/31/2012

In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. §2031.220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P....more

Quoting Shakespeare

by Katherine Gallo, Esq. on 1/13/2012

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?

by Katherine Gallo, Esq. on 12/13/2011

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"?

by Katherine Gallo, Esq. on 11/8/2011

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!

by Katherine Gallo, Esq. on 7/26/2011

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

by Katherine Gallo, Esq. on 4/7/2011

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

by Katherine Gallo, Esq. on 3/9/2011

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

Managing Construction Litigation in the Information Age

by Michael Raneri on 7/21/2010

This article discusses ways to manage construction documents well prior to the litigation phase to save your company time, effort, and most importantly, on your bottom line....more

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Electronic Discovery › Construction Law