Except as provided in 3.1345 (b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. endstream endobj 627 0 obj <. Yj;r/triZ!fGsp0e, Ct. (1980) 111 Cal.App.3d 902, 905-906.) Please wait a moment while we load this page. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. )~?0}nF]q q3} ^+w-\_CRwh0`g}*NtOFN/>e2NtqNL1i}N^hJ"I@J$/:X\I58.WC5 -/I1_BH)"EAse,"-KhSEK xme (Code of Civ. ~EbS0G#z`BW'w7f**C I~0Ct$M2/{e}7F6gSJO*>R+O]SV/a We noticed that you're using an AdBlocker, Motion to Compel Discovery Responses (CCP 2030.300). See California Civil Discovery Practice, 4th Edition, (CEB 2019) 3.157A citing Williamson v. Superior Court (1978) 21 Cal3d 829, 835; Hill v. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Form Interrogatories, Set O ..Centinela Gas Station, Inc. (Centinela) (collectively, Defendants). y6[R}Jv+StG]{K'TR}%swsM/QN^;h{9w~*l 4M`e\ m^7q@?|UL\k:xKmt3 Proc. California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. (Theres a $15 off Coupon Code at the bottom of the page.). Proc., 2033 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION endobj Proc., 2030.290(c), 2030.300(d), 2031.310(h); see also Code Civ. Unsworn responses are tantamount to no responses at all. (Appleton v. Super. We will email you jrIe_LHz~7Vd7Vs*V+7JrHurD8|I!WK44e#Bf*.8xUdKhOj/2>Cq5:$JV !|I|JNWc ?u_xRK+JNI^hAGF0j\V qB*Po0, ), The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. Hearing Date: 2022 California Rules of Court. may be governed by the Code of Civil Procedure (C.C.P.), the California Rules of Court (C.R.C.), local court rules, or all three. These consequences can be eliminated by using LBTN, which pulls together the C.C.P., C.R.C., and Judicial Council forms for commonly-encountered tasks in California state court civil litigation cases, and explains them, step-by-step. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. Note: Identify the interrogatories in question by name and set number. Dept: If you wish to keep the information in your envelope between pages, TRADER JOE'S COMPANY ET AL, Motion filed - Motion to compel further responses to special interrogatori, Christina Zamora vs. Fresno Community Hospital Medical Center, MEMORANDUM OF POINTS AND AUTHORITIES FILED RECORD SEALED - Plaintiff's Mem, Motion to Compel Further Responses to Interrogatories, Motion to Compel Responses to Request for Production of Documents, Motion to Compel Deposition of Person Most Qualified (PMQ). Suite 210 183 <> HEARING DATE: endobj (See, e.g., Code Civ. SC129356 MOTIONS Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. (Code Civ. It provides an overview of the meet and confer requirements, standards for compelling discovery, and discusses the procedural steps for making a motion to compel discovery. [. endobj <> Your alert tracking was successfully added. Compelling Inspection or Production: [CCP 2031.300(c)]. : M~2G,pwo}mE`^2> rVM]+|y1# ms~^L|.c9W(_FK We have notified your account executive who will contact you shortly. These codes, rules, and forms change often! (Code Civ. When calendaring deadlines, one must also be mindful of all of the California state court holidays; they differ from the list of Federal holidays). sT9xo i),}KJKyXc*XY:LP-20W Requests for Admissions Grounds For Motion- A party may move to compel responses or additional responses to Requests for Admission if (1) a response was evasive or incomplete, or (2) an objection is made that is too general or without merit. 8 [This, too, is covered in LBTN. 3 0 obj Background Each answer to a propounded interrogatory must be as complete and straightforward as the info Jackson v. Feraj, et al. I. These include what has to be in the title and below the title, what has to be in the opening paragraph, what to include when monetary sanctions are sought, the required parts of a motion and what must be included in each, form of exhibits, proper binding, proper numbering of pages, etc. will be able to access it on trellis. Proc., 2023.010.) The list of telephone numbers of LASC Judicial Officers is online. 2443 Fair Oaks Blvd. Code Civ. California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. Consultants (2007) 148 Cal.App.4th 390, 405.). Proc., 2030.260(a), 2031.260(a). TENTATIVE RULING: Proc., 2030.260 (a), 2031.260 (a) .) (Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1586-1587 (the fact that a party does not have a right to have a discovery motion heard after the discovery motion cutoff date does not mean the court has no power to hear it, or that the court errs in hearing it.)), A party may obtain relief from a waiver of objections to interrogatories and a request for production when the party subsequently serves responses and the failure to serve a timely response was the result of a mistake, inadvertence, or excusable neglect. Proc., 2031.310(c); 2030.300(c). It is . Notice: Once you have your hearing date, you must calculate the last day to serve your notice and moving papers. (See also Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893 (trial court did not abuse its discretion in denying plaintiffs motion to compel discovery as plaintiffs separate statement did not comply with the rules of court); Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145 (trial court properly denied motions to compel discovery because of nonconforming separate statements). (See, e.g., Code Civ. Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above]. Motions to compel further responses to written discovery must be brought within 45 days (50 days if by mail) after service of the insufficient responses. In Sacramento, motions to compel responses to discovery are heard in either Department 53 at 1:30 p.m. or Department 54 at 9:00 a.m . endobj On April 6, 2020, Defendant filed Requests for Jud Case Number: Plaintiffs Motion to Compel Defendant to Provide Further Responses and Request for Sanctions is DENIED. April 30, 2021 Legal Standard VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Compelling Deponent to Answer or Produce Documents: [CCP 2025.480(f)]. The responding party has 30 days after the service of requests to object and answer. (Code Civ. plain reading of California Rule of Court, Rule 3.1345(a), which provides that a separate statement is required for "[a]ny motion involving the content of a discovery request or the responses to such a request." The present motion to compel compliance does not involve the content of a discovery request or response. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories M <>/Metadata 134 0 R/ViewerPreferences 135 0 R>> The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories [NUMBER] On February 4, 2019, Plaintiff Benjamin Lieu (Plaintiff) filed an action for motor vehicle negligence against Defendant Miao Jing (Defendant) .., Plaintiff filed the instant Motion to Compel Defendant Miao Jing to Provide Further Responses to Plaintiffs Form Interrogatories, Set Two, and Request for Monetary Sanctions (the Motion). Instead, attach the cover page of the deposition (stating the party names) and the relevant pages of the deposition transcript, with relevant portions highlighted, to a supporting declaration to the motion. Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031.280, 2023.050, and 2016.090. You have to know how to count to that 45th day, what to do if that day lands on a holiday or weekend, and, where the responses were not personally served, how many days by which to extend that 45-day deadline. endobj 1228 0 obj <>/Filter/FlateDecode/ID[<5D648DF4CF0B8D4198F297B63189C2D3>]/Index[1204 61]/Info 1203 0 R/Length 117/Prev 414673/Root 1205 0 R/Size 1265/Type/XRef/W[1 3 1]>>stream Last. CRC 3.1113(m) (amended eff 1/1/17), A written notice and all moving papers supporting a motion to compel an answer to a deposition question or to compel production of a document or tangible thing from a nonparty deponent must be personally served on the nonparty deponent unless the nonparty deponent agrees to accept service by mail or electronic service at an address or electronic service address specified on the deposition record. 178 179 Couns., Inc. v. Pac. 13 0 obj (3) An objection in the response is without merit or too general. %PDF-1.6 % try clicking the minimize button instead. (CCP 2030.300) 1005(b), are just different enough from the extensions mentioned above to make it dangerously confusing (2 calendar days under one scenario; 2 court days under another). % Your recipients will receive an email with this envelope shortly and Now, assuming you find all of the applicable codes and rules for this early part of the process, it is not enough to simply read them. Factual support and legal argument as to why an additional response should be compelled. 10 0 obj (12/6/18 Stipulation.) 3d 902, 905-906.) Adding your team is easy in the "Manage Company Users" tab. (2) An order staying further proceedings by that party until an order for discovery is obeyed. X {5j7"qWz+?(;ya n5kOx'nWT_y0:O|q$}c'y$[LH}?2[O.vDb6c@ !Iy|ms TENTATIVE RULING: Meet and Confer Declaration Required. 0 Your subscription was successfully upgraded. Ct. (1980) 111 Cal.App.3d 902, 905-906.) <> Your subscription was successfully upgraded. 1005(b)) Service must be made earlier if the papers are not personally served. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; 1264 0 obj <>stream @(%DuI 6v{X+EL. (C.C.P. : Failure to timely respond waives all objections, including privilege and work product. Code Civ. [CCP 2031.310(b)(2)]. 1*|,/XnLRGCH\y*XEU^ z3[Afs] 647 0 obj <>stream <> The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed (Cal. April 30, 2021 ), Note, in Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1588, the court held that, [b]y simply hearing the motion to compel without first deciding whether discovery should be reopened for that purpose under all of the relevant circumstances, the trial court transgresse[d] the confines of the applicable principles of law and thereby abused its discretion. (citing, in part, City of Sac. See (Objection (Doc. Otherwise the requesting party waives the right to move to compel further responses. 4 0 obj Proc., 2033.290(a).) : <> C.C.P. Meet and Confer Declaration Required. You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. ), The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. CRC 3.1304(c) &(d) (amended eff 1/1/16). endobj %%EOF Parties may also move to compel further responses as to interrogatories on similar grounds. Under Federal Rule of Civil Procedure 26, generally "a party may not seek discovery The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Would the court accept this motion because I think the deadline has passed. EXTRA SPACE STORAGE, INC. (e) Making, without substantial justification, an unmeritorious objection to discovery. (3) An order dismissing the action, or any part of the action, of that party. Your recipients will receive an email with this envelope shortly and endobj (Code Civ. To date, no reply brief has been filed. This section titled Power of Court to Allow Motion to Submit Tardy Expert Witness states: (a) On motion of any party who has failed to submit expert witness information on the date specified in a demand for that exchange, the court may grant leave to submit that information on a later date. Proc., 2030.290(c), 2030.300(d), 2031.310(h); see also Code Civ. endobj Proc., ), Sanctions include attorney's fees. Many types of discovery motions require the moving party to submit a "meet and confer" declaration. endobj This could vary from two court days to five calendar days to ten calendar days, depending upon the service method and, when served by mail, the location of the parties. relies on Litigation By The Numbers (LBTN), the essential California civil practice guide updated twice yearly. Compelling Further Response to Inspection Demand: [CCP 2031.310(d)(h); CCP 2031.320 (b)]. On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. Legal Standard (CCP 2030.300, 2031.310) Previous questions relied on by the question at issue (for instance, if a question says, if the response to interrogatory #1 was affirmative, please state you may have to include interrogatory #1 and its response for reference). 177 1005(b)C.C.P. by Julie A. Goren | Jan 15, 2022 | Articles. ), Sanctions include attorney's fees. Parties may also move to compel further responses as to interrogatories on similar grounds. New Rules First, when responding to requests for production, the produced documents must identify the specific request to which they respond . hbbd``b`$W- b+qs' AH? b``M 9 The motion to compel further responses has to be brought within 45 days of service of the response. Ct. (1980) 111 Cal. The extensions, found in C.C.P. Thus, you should meet and confer on any deficiencies as soon as possible to allow time for you to review supplemental responses and prepare your motion to compel, if needed. : Sanctions for failure to provide discovery. 1000 We will email you 12c solves that: count backward from the hearing 16 court days and then add the applicable extension. endobj On receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that any of the following apply: On receipt of a response to an inspection demand, the party demanding an inspection may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete. Dept: Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions 175 Rule 3.1348. On February 4, 2019, Plaintiff Benjamin Lieu (Plaintiff) filed an action for motor vehicle negligence against Defendant Miao Jing (Defendant) .., Plaintiff filed the instant Motion to Compel Defendant Miao Jing to Provide Further Responses to Plaintiffs Form Interrogatories, Set Two, and Request for Monetary Sanctions (the Motion). To date, no reply brief has been filed. Drafting, filing, and serving a motion to compel further responses and calendaring all associated deadlines demands strict compliance with scores of requirements. 9l^Jg,E,sz?k=1T OZ@[{q~dG{c{l)SIG :4L~h{t-s+}:p3. The motion to compel further responses has to be brought within 45 days of service of the response (CCP 2030.300). 180 when new changes related to " are available. Proc., 2030.260(a), 2031.260(a). 5 <> (d) Failing to respond or to submit to an authorized method of discovery. Before moving to compel discovery responses, California law requires that the parties "meet and confer." . 4/30/2021 Title 3, Civil Rules-Division 11, Law and Motion-Chapter 6, Particular Motions-Article 5, Summary Judgment Motions renumbered effective January 1, 2009; adopted as article 4 effective January 1, 2007. (i) Failing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning discovery, if the section governing a particular discovery motion requires the filing of a declaration stating facts showing that an attempt at informal resolution has been made. GOOD FAITH DUTY TO RESPOND . ), PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED, COMMON COUNTS/OPEN BOOK ACCOUNT/COLLECTIONS, OTHER NON EXEMPT COMPLAINTS (For Unfair Competition In Violation Of Cal. endobj CASE NAME: THOMPSON VS CONTINENTAL LABOR RESOURCES, INC. Motion to Compel 01/26/2018 - Motion to Compel, Motion to Compel Further Responses to Interrogatories, Motion to Compel Responses to Request for Production of Documents, Motion to Compel Deposition of Person Most Qualified (PMQ). 182 On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. |$9hB3.ma^%]tX`s6LHi#cebB)>_CZ0CjGmV;P -Q:"H,eOx#G" ,yDF.`E%RS=i Proc., 2023.030(a), 2033.280, 2030.290, and 2031.300. 2030.300) Certain types of cases in certain courts, e.g., Personal Injury Actions in Los Angeles county, might also require an informal discovery conference with the judge before bringing the motion. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. 9 Defendants' motion to compel should be denied. MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION 6 0 obj A misstep at any point may result in denial of the motion and a waiver of the right to compel further responses. Accessing Verdicts requires a change to your plan. Proc., 2031.310(c); 2030.300(c). Your content views addon has successfully been added. ARGUMENT . SmartRules only services accounts in the United States and customers with special access needs from abroad. hb```B eaXhz Le \X47nz;&*zn9q fg8)k'>%kEg??mI6+9Z~Xl^sd6ob`T Li In response to the motion to compel, the Defendants charge that the discovery requests by the Plaintiff exceed the limits set by the Court. mailed from California to an address in California, five calendar days are added before the sixteen court days. ( ), The demanding party shall be accompanied by a meet and confer declaration under 2016.040, or a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Proc., 2025.450(c)(1). Code 70617(a)C.R.C., Rule 3.1110C.R.C., Rule 3.1112C.R.C., Rule 3.1113C.R.C., Rule 3.1308C.R.C., Rule 3.1345, Yes, every one of those codes and rules governs some aspect of the procedure for drafting, filing, and serving a motion to compel further responses to interrogatories. Plaintiff also refiled the Motions on March 25 and 30, 2020 with accompanying declarations and separate statements. The failure to file a written opposition or to appear at a hearing or the voluntary provision of discovery shall not be deemed an admission that the motion was proper or that sanctions should be awarded. 4 0 obj pD1visp[n5pL3lQtM;-a-VO}]ny]t;pcgj(q =vwVB~dm$ 4H^~#Ead4*KSj:sLGLvBSHr$$UKe;vtT='l6tdfIKq5'H=l#?JzT=A?qjf)$d?RTia&p%NoD]FYD/}@J!>1Za{JZ:LigFmhHgSLI a^xrJgr,6l_. ], Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, a concise outline of the discovery request and each response dispute.. I. Amit Lal vs University of the Pacific, a California Corporation et al. ANALYSIS: California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. Your subscription has successfully been upgraded. You have to digest, understand, and correctly apply them. 185 <> The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (e)(2).) 2030.300Govt. that will have to be applied correctly to ensure that the moving papers are complete and in the proper format, the motion is brought timely, filed in the correct place with the correct filing fee, the papers are served correctly and timely, and more. [LBTN has an entire chapter devoted to Filing, Service, and Calendaring. It includes detailed information about each method of service, when they are authorized, the various extensions of time, and detailed instructions on calculating deadlines. Sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution, Notice of Tentative Ruling Required in Notice The Notice of Motion must include the following text: Pursuant to Local Rule 3.04, the court will make a tentative ruling on the merits of this matter by 2:00 p.m., the court day before the hearing. Moreover, one must know how to count the days: is it backward from the hearing date or forward from the notice date? Although the California Civil Discovery Act does not require a meet and confer prior to filing a motion to compel initial responses, See CCP 2031.300, on [Date], Plaintiff sent a Meet and Confer Letter to Defense Counsel, ruesting verified substantive responses, eq unilaterally allowing additional days to provide verified substantive responses. Thats why everyone in the law office, from the most experienced litigator to the most inexperienced trainee (attorney, paralegal, legal secretary, etc.) Of course if you are on the receiving end of the motion to compel, youll need to know your deadline for opposing the motion, the format for doing so, etc. Meet and Confer Declaration Required. The motion must include a a good faith declaration, stating that the attempt was indeed made. [LBTN explains these requirements and provides easy-to-follow examples. But the court allowed the late motion to compel if the moving party undertook some steps. We noticed that you're using an AdBlocker, Motion to Compel Discovery Responses (CCP 2030.300). The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; Compelling Further Responses After Insufficient Responses. (Leach v. Super. Meet and confer: A prerequisite to bringing a motion to compel further responses is a reasonable and good faith attempt to informally resolve the issues presented by the motion. <> ), Rules of Court, rule 3.1348(a), explains, The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after motion was filed. (See also Code Civ. x[oJr)7 y$r$ YyAYO=_lr>$@lvWI}(PMYwUeM^u[|Qc]|,Wst]y_Uk]]5e]^./C+xYUnjw_ ZwjovxN4rE 7e];)c]vQB{g+Uf]uoOo;cpf~.}"nDz NUjK{UVMyuS,_,\_/%bwiG}eauS^B`Cc[^|+/>,1 F"H#wH~-Iu?[R <> SC129356 If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the insufficient responses. ), The statute contains no time limit for a motion to compel where no responses have been served. Again, an exception exists if the responses were not created in an electronic format. Accessing Verdicts requires a change to your plan. "E McR&Ih0T;6g,ya8aO3F%H>r!mj)ETe} f3=eK5"n2HCa+x|Fz~1PR4:o\R9tBbP8-Qy}c WxmMe1)`Msq+H;B_@9)X1#q?d,.~'ZNb3PZY2uJr`E7[ Z,y (Code of Civ. Proc., 2030.290(a), 2031.300(a).) TENTATIVE RULING: Format of discovery motions (a) Separate statement required Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Ask Your Own Family Law Question. R"'4-32bY/h?}vd$y|M#f"5[6qKQ>2UbPvq%]hR4j2}zIo)18O1mQ| 1s|@U 9 0 obj Brian Leung v. Alireza Alivandivafa Fortunately theres help: LBTN guides the reader through these steps. %%EOF 7 0 obj Proc., 2030.290(a), 2031.300(a). MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories endobj Compelling Further Response Request for Admission: [CCP 2033.290(d)]. CASE NO. On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. A single procedure (e.g., filing a complaint, answering a complaint, filing a motion, opposing a motion, serving discovery, responding to discovery, etc.) Motion ..quest is evasive or incomplete. 18 0 obj Most judges require reservation of hearing dates. Sanctions for failure to provide discovery (a) Sanctions despite no opposition The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party . Ct. (1980) 111 Cal. 3 On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. endobj 16 0 obj If you need legal advice, you should contact a lawyer. This Motion is made pursuant to 2030.290(b) and is based upon this Notice of Motion and Motion, the accompanying Memorandum of Points and Authorities, the Proc., 2033 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION %PDF-1.7 #379 See Code of Civil Procedure 5 6 Section 1005 for more details. 12cC.C.P. Monetary sanctions: If sanctions are sought, C.C.P. 2030.300) Sounds simple enough, but its not. (f) Making an evasive response to discovery. Plaintiff Nicole Jacksons LLCs (1) Motion To Compel Further Responses To Form Interrogatories, Set One; Request For Monetary Sanctions; and (2) Motion To Compel Further Responses To Requests For Production, Set One; Request For Monetary Sanctio ..s to Compel Further Responses on September 12, 2019. (Thats only the beginning of the process!). (Code of Civ. u%-T\=\5j8XZjH6/A Pga$plDW;XSVLiY5$Lz3V.)g[JD?aRP#e)6(]_$^"JcJ*YiMQV x[[o:~}bUH]"@$,M7>h ~gD]ZM$r8G}>~yzycvz6e;$\0oV,e.8Hx,c/}c Gz?Glovs1G!Bq%aC'^,Xn!D nfCLpZ(gxOQ'i1OQVna1`E/py?jEcc/YXOZ)_yZ +* 0bBzA@r#E+ky0&=psSrg {|/(/~btMq]_^S']/7t>iQ( S Reply in Support of Motion to Compel Discovery, Reply in Support of Motion for Leave to File Cross-Complaint, Reply in Support of Motion for Preliminary Injunction.
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