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It's the year 2009. The 21st century has begun in earnest, and the technological advances promised by futurists and science fiction writers have arrived, haven't they? Children have cell phones and cars have voice-activated navigation systems. No one can escape the march of progress, even time-honored professions inherently resistant to change, like the practice of law. Today's lawyers simply cannot function without computers, Internet access, e-mail and electronic documents. The federal judiciary boasts that electronic filing of documents is now mandatory in 99 percent of all federal courts. But has the future arrived in California's courts? Two recent court of appeal opinions make clear that California's rules of practice have not kept pace with the technology actually used by courts and the lawyers.

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