Electronic Discovery, Personal Injury, Products Liability

COITO v. SUPERIOR COURT--Is It Heading Back to the Supreme Court?

by Katherine Gallo, Esq. on 9/23/2012

On August 14, 2012, Judge William A. Mayhew of Stanislaw Superior Court issued his Notice of Hearing on Issues Re Remand in the case of Debra Coito v. State of California. The order requested that the following issues to be...more

Acted With Substantial Justification

by Katherine Gallo, Esq. on 9/5/2012

Just wondering, but what does the phrase "acted with substantial justification" mean in the sanctions statute for motion to compel depo testimony, CCP 2025.480 (pdf)? Does it mean the conduct that led the moving party to...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

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

eDiscovery Brings Civil Litigation Online

by DepoTexas on 9/20/2011

Lawyers across the country are saving trees and their sanity with new eDiscovery solutions....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

How to Write Requests for Admissions

by Katherine Gallo, Esq. on 2/15/2011

Requests for admissions may be used to (1) establish the truth of specified facts, (2) admit a legal conclusion, (3) determine a party’s opinion relating to a fact, (4) settle a matter in controversy, and (5) admit the...more

Why Aren't You Using Requests For Admissions

by Katherine Gallo, Esq. on 2/1/2011

If you are like most lawyers, you are using the typical discovery devices to gather up all your information--form interrogatories, special interrogatories, requests for production of documents, and of course the deposition...more

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Electronic Discovery › Personal Injury › Products Liability