Katherine Gallo, Esq.
Law Offices of Katherine Gallo

969G Edgewater Blvd.
Suite 345
Foster City, CA 94404, United States
Phone: 650-571-1011
Fax: 650-573-8446
Areas of Practice
  • Alternative Dispute Resolution (ADR)
  • Litigation

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


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
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