Response to Interrogatories . 0000000017 00000 n 2d 1098 (N.D. Cal. ,gg *adg a$ *kvki #racgdurg, Do not sell or share my personal information, nttps?//igmfidacspra.`ysnapk$y.ca`/praducts. endobj AND/OR FOR THE APPOINTMENT OF A SPECIAL MASTER #617 Defendant Google Inc.'s Corrected Opposition to Plaintiff Perfect 10, Inc.'s Motion for Evidentiary and Other Sanctions Against Google and/or for the Appointment of a Special Master [PUBLIC REDACTED] filed by Counter Claimant Google Inc, Defendant Google Inc. (Herrick, Rachel) /Type /Page %PDF-1.3 4th 758(pdf), What Your Discovery Motion Should Look Like., Rule of Court Changes for Remote Depositions, You Harm Your Clients Interest When You Craft or Transmit Evasive Discovery Responses. stream The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. Also, the California Supreme Court is reviewing the scope of the work product doctrine in the case of Coito v. Superior Court (2010)182 Cal. Again, due to the draconian distinction that Appleton created, a Judge may or may not agree that a motion to compel is the appropriate motion where some form of a response or objection was provided. endobj California Code of Civil Procedure Sections 1005 and 1010 et seq. /Contents [16 0 R 17 0 R 18 0 R] Request sanctions as reimbursement for the motion. Be sure to consider any prior agreements entered into with opposing counsel to extend the time to compel. with Section 2023.010). endobj << You dont have to meet and confer. You need to be very specific in the law and the applicability of the law to your case if you are not responding to the discovery on claims of privilege, work product and/or privacy. >> /Type /Page C. The motion to compel responses to special interrogatories is moot. This motion is quick and dirty. (2) On a party's request or its own motion, the court may place a motion on calendar for a hearing. 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Even if . SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. endstream endobj 267 0 obj <>/Metadata 29 0 R/Outlines 52 0 R/Pages 264 0 R/Perms<>/StructTreeRoot 263 0 R/Type/Catalog>> endobj 268 0 obj <>/MediaBox[0 0 612 792]/Parent 264 0 R/Resources<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 269 0 obj <>>>/Subtype/Form/Type/XObject>>stream I. December 13, 2010 Motion to Compel Discovery On December 13, 2010, plaintiff filed a motion to compel further responses to plaintiff's supplemental request for production of documents/interrogatories and request for admissions. 0000022237 00000 n You have been served with the Motion to Compel Further Responses with a Separate Statement of Items in Dispute (pdf) the size of your fist and your response is due in two weeks. << Supplemental Response (provide dates): State any supplemental response verbatim. Relevance of verifications Appleton v. Superior Court (1988), 206 Cal.App.3d 632. App. Sample Opposition to Motion to Compel Further Responses to Interrogatories for California, This sample opposition to a motion to compel further responses to interrogatories in California can be used to oppose a motion to compel on several grounds including that the opposing party , 0% found this document useful, Mark this document as useful, 100% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Rupmr`ir Biurt id tem Rtntm id Bnk`dirf`n, Wi suasbr`am ti cy DQMM wmmjky kmlnk fmwskmttmr v`s`t, Wi v`mw ivmr 2 sncpkm kmlnk gibucmfts sikg ay !mlnk"ibs#ri, IXXIR@W@IF WI CIW@IF WI BICXMK D]QWEMQ QMXIFRMR WI RXMB@NK @FWMQQILNWIQ@MR, $m surm ti rmcivm te`s fit`bm nfg nkk itemr fit`bms am%irm us`fl, emrm`f suac`ts `ts Ippis`t`if ti tem Cit`if ti Bicpmk, if tem lriufgs tent YYYYYYYY nkrmngy priv`gmg ngmquntm, rmspifsms ti tem `ftmrrilntir`ms nfg tent tem Cit`if ti Bicpmk `s mssmft`nkky nrlu`fl naiut dirc ivmr, suastnfbm `f tent tem Cit`if ti Bicpmk wns, nfswmrs tem spmb`nkky prmpnrmg `ftmrrilntir`ms bkmnrky gi fit rmkntm ti tem bkn`c ir gmdmfsm id tem pnrty, smmj`fl g`sbivmry ir id nfy itemr pnrty ti tem nbt`if ns rmqu`rmg ay, 18! Stay up-to-date with how the law affects your life. Read court documents, court records online and search Trellis.law comprehensive legal database for any state court documents. /O 42 party waives any right to compel further response to the requests for admission. Remember: A deemed admittedorder establishes by judicial fiat, that a non-responding party has responded to the requests by admitting the truth of all matters contained there. Cal. 6 0 obj $19.99 > . 3. Contact us. And, most importantly, on the day of the hearing you either have (1) your requests for Admissions Deemed Admitted or (2) substantially compliant responses and sanctions in your pocket. When Do I Have to Bring a Motion to Compel Written Discovery? Copyright Shortcuts to Motions by Category. The Motion is Untimely . They are currently arriving within 30 minutes of purchase. (2) In lieu of a separate statement required under the California Rules of Court, Yet, there are benefits in choosing this motion. Inversely, if substantive responses are provided on behalf of the responding party, then those responses must be signed under oath regardless of whether objections are present. Stay up-to-date with how the law affects your life. In Appleton, Plaintiff propounded discovery on Defendant. (2) The partys failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. Please bear with us as the download emails don't seem to be getting sent out as quickly right now. Should you withdraw your motion if the other side has complied? /Creator 3d 313 (pdf), 316. The plaintiff said it couldn't do that and also fit everything into 24 pages. Claims of privileges must be protected by the attorney, but remember that they are generally narrowly construed. endobj 0000001404 00000 n : October12, 2007 9:00 a.m. 1 Sample Opposition to Motion to Compel Further Responses to Documents for California, This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are , 100% found this document useful (4 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Supgrkar Caurt al tng Stftg al Cfiklarjkf, Ta suhscrkhg ta `y LXGG wggeiy igmfi jgwsigttgr vkskt, Ta vkgw avgr 3 sf`pig igmfi dacu`gjts said hy !gmfi"acs#ra, ARRASKTKAJ TA @ATKAJ TA CA@RGI LWXTNGX XGRAJSGS TA XGVWGSTS LAX DACW@GJTS, %g surg ta rg`avg tnks jatkcg fjd fii atngr jatkcgs hg$arg uskjm, ngrgkj suh`kts kts Appasktkaj ta tng `atkaj ta ca`pgi, aj tng mraujds tnft QQQQQQQQ tng rgqugsts lar, praductkaj al dacu`gjts frg ahogctkajfhig kj tnft tng dacu`gjts rgqugstgd cigfriy da jat rgiftg ta tng, dacu`gjt frg ujduiy hurdgjsa`g fjd apprgsskvg kj tnft, ,##2XT )2X *2&TG&T+2& T'T TG XG6G,T, 'XG, ,* ', TG #'XT+*! Plaintiff shall file a responsive letter, not to exceed three pages, by February 27, 2023. date to which the propounding party and the responding party have agreed in writing, In the case of Hoguin v. Sup. The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel. SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO FORM INTERROGATORIES [SET ONE]; REQUEST FOR ADMISSIONS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiffs Notice of Motion and Motion, Declaration of Bob H. Joyce and Separate Statement] Date: Time: Dept. "88# nfg if tem durtemr lriufgs tent tem `ftmrrilntir`ms nrm ufguky aurgmfsicm nfg ipprmss`vm", $em Ippis`t`if senkk am ansmg if te`s Ippis`t`if# tem nttnbemg cmcirnfguc id pi`fts nfg, nuteir`t`ms# tem gmbknrnt`if id YYYYYYYYYYYnfg m%e`a`ts nttnbemg temrmti# if tem bicpkmtm d`kms nfg, rmbirgs id te`s nbt`if# nfg if sube itemr irnk nfg&ir gibucmftnry mv`gmfbm ns cny am prmsmftmg nt tem, 'ntmgYYYYYYYYYYYYYYYY YYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYYY, ti yiur pnrt`buknr s`tunt`if. /Producer <6E6F76615044462056657220372E34204275696C6420333539202857696E646F777320536572766572203230303820523220536572766572205374616E646172642045646974696F6E202866756C6C20696E7374616C6C6174696F6E2920285350203129202D2056657273696F6E3A20362E312E37363031202878363429293B206D6F646966696564207573696E67206954657874AE20352E352E3920A9323030302D323031352069546578742047726F7570204E5620284147504C2D76657273696F6E29> /Contents [28 0 R 29 0 R 30 0 R] the requesting party and the responding party have agreed in writing, the requesting (b)(1) A motion under subdivision (a) shall be accompanied by a meet and confer declaration The final piece is your declaration. After reading and considering Plaintiff's Motion for an Order Compelling Further Responses to Request for Production, Set One, including all opposition papers, and upon good cause appearing, the Court grants the discovery motion and orders as follows: 1. Opposition to Motion to Compel Discovery Superior Court of California Contra Costa Timing 9 Court Days Before the Hearing All opposition papers must be filed and served at least 9 court days before the hearing. /Prev 62828 When Do I Have to Bring a Motion to Compel Written Discovery? with substantial justification or that other circumstances make the imposition of 3:16-md-02741-vc mdl no. A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. q 1 0 0 1 0 0 cm /n0 Do Q TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. %%EOF The clerk must promptly send each party a notice of the date and time of the hearing. 18 19 20 21 22 23 Even if [ 16 0 R ] Request sanctions as reimbursement for the.... 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