Katherine Gallo, Esq. – Law Offices of Katherine Gallo

The Pitfalls of Bad Discovery Habits

For years I have been blogging about bad discovery habits from my blog on Garbage Objections to my blog on unauthorized General Objections, and preached that attorneys must play by the rules. As you know if you have read my…more
|

WHAT IS WRONG WITH THE CURRENT CMO PROCESS IN CONSTRUCTION LITIGATION? And yes, there is a better way!

At the 22nd Annual West Coast Casualty Seminar, Plaintiff counsel Michael Kennedy, General Contractor Counsel Matthew Hawk, Subcontractor Counsel Brian Sanders, Claims Manager James Rzpecki and I presented a new protocol for how…more
|

Case Management Order #3 -- Trial Deadlines

California Complex Case Management Order re: Trial Deadlines…more
|

Construction Case Management Order #2 -- After Mediation

California Construction Case Management Order #2 to be used after the first mediation…more
|

Construction Case Management Order #1 Day 0 - Day 180

First Case Management Order for Construction Litigation in California…more
|

Without Consent of the Parties...

If you perform a Lexis search using the words “Special Master” in the Code of Civil Procedure you will find “no results.” This is because there is no statutory authority for such an appointment. Yet, in the area of Construction…more
|

Proposed Form Interrogatories for Construction Litigation

In May of 2007, I received a phone call from Peter Glaessner, a member of the Discovery Committee and Civil and Small Claims Committee of the Judicial Council. He asked me if I could put together Judicial Council Form…more
|

Can You Take a Deposition in Seven Hours?

California Code of Civil Procedure §2025.290 (effective January 1, 2013) limits Non-Expert Depositions to 7 hours. The section reads: Unless otherwise stipulated to or ordered by the court, a deposition is limited to one day…more
|

Why Every Insurance Carrier Should Insist That The California Construction Form Interrogatories Be Used

It is generally recognized that construction defect cases are some of the most expensive, and complicated, cases being litigated in California. I have personally been involved in cases with more than 75 payers contributing to a…more
|

You Have the Right to Conduct Discovery

Last week I received a phone call from an attorney asking what is the authority that says a party has the right to conduct discovery. I responded, “The Discovery Act!” Counsel stated that they needed more because a special…more
|

When Discovery Abuse is a Trial Strategy

During one of my discovery seminars, I was asked how do you handle discovery abuse when it is part of a deep pocket defendant’s litigation strategy. His story went like this: Plaintiff's counsel had been to court several…more
|

Discovery Plan--The Year Before Trial in a Complex Case

Somewhere in the back of your mind you are aware that discovery and Motions for Summary Judgment deadlines are looming. Yet, you really don't pay attention to them until they are upon us usually around day 45 when you start…more
|

Should You Withdraw Your Motion if the Other Side has Complied

I have always been a strong advocate that you should be awarded sanctions if you had to bring a motion to get the relief you were entitled to even if the other side complied prior to the hearing on the motion. However in the…more
|

2016 New Years Resolution New Requirements for Deposition Notices

There was only one change to the Discovery Codes but it was significant. The legislature added language to Code of Civil Procedure Section 2025.220 with added requirements when you serve a deposition notice. The deposition…more
|

Is the Court Correct That There is No Motion to Strike in Discovery?

Recently I received an e-mail from an attorney who followed my advice regarding General Objections. It went like this: Recently I received an e-mail from an attorney who followed my advice regarding General Objections. It…more
|
Showing 1-15 of 63 Results
|
View per page
Page: of 5
Contact

969G Edgewater Blvd.
Suite 345
Foster City, CA 94404, United States

  • 650-571-1011
  • 650-573-8446

Areas of Practice
  • Alternative Dispute Resolution (ADR)
  • Litigation
Badges
Verified
This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×