GIve Me All Your Documents!

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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 (consistent with California Evidence Code Section 250), including but not limited to job files, building contracts, agreements, notes, correspondence, photographs, videotapes, diagrams, plans, specifications, shop drawings, “as-built” plans, calculations, journals, invoices, purchase orders, change orders, addenda reports (including reports prepared by consultants and design professionals for the original construction), job diaries, receipts, project files, site records, daily job logs, field orders, superintendent reports, requests for clarification, requests for information, time cards, governmental inspection punch lists and sign off sheets and invoices relating to the construction, repair, or maintenance of the real property involved in this lawsuit.

There are so many things wrong with this request I do not know where to begin.

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Published In: Civil Procedure Updates, Construction Updates, Electronic Discovery Updates, Personal Injury Updates, Products Liability Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Katherine Gallo, Esq., Law Offices of Katherine Gallo | Attorney Advertising

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Katherine Gallo, Esq.
Law Offices of Katherine Gallo

Katherine Gallo actively involved in Alternative Dispute Resolution (ADR) as a court-appointed... View Profile »


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