California discovery referee and mediator Katherine Gallo authors the Resolving Discovery Discovery Disputes blog. Bringing a wide range of services as a Discovery Referee/Special Master and an extensive background mediating cases in a variety of practice areas, Kathy uses this publication to comment on topics that include interrogatories, sanctions, objections and abuse.
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Last week I received the following e-mail from one of my readers: I have read your articles with interest and respect for some time now; I find them excellent plus. I have a friend who is acting pro per in a civil case. Suffice it to say she can't afford or get an attorney. Opposing counsel has...
Today I read a great article by Minnesota attorney Randall Ryder titled "New Attorney? Don’t Get Intimidated by Opposing Counsel." The article struck a cord with me as it is a proponent of the same philosophy that I am advocating in my own blog—don’t be intimidated by a...
In responding to Requests for Production of documents you have three response choices (1) agree to produce (C.C.P. §2031.220 (pdf)); (2) state that after a diligent search and a reasonable inquiry you have no documents (C.C.P. §2031.230 (pdf)) or (3) object C.C.P. §2031.240...
Last spring I had the pleasure of taking a tour of the Royal Globe Theatre in London, England. On display there was a plaque titled “Quoting Shakespeare.” It began by stating: IF YOU CANNOT UNDERSTAND MY ARGUMENT AND DECLARE, “it’s Greek to me, you are quoting...
To determine whether or not a responding party has made a reasonable inquiry, you must determine where the responding party searched (what efforts were made), who did they talk to (did they make an inquiry to their legal department, human resources, customer relations, the employees in the chain...
Have you ever received a response to requests for production of documents that says: After a diligent search and a reasonable inquiry has been made in an effort to comply with this Request, there are no documents within RESPONDING PARTY’s possession, custody, or control Yet you question...
You are now sitting down to organize your Discovery Plan and determining what discovery you need to evaluate your case, prepare for mediation, file a motion for motion for summary judgment/summary adjudication and/or get it ready for trial. But where do you start? My suggestion is to litigate like...
As every lawyer is aware, a party may propound more than 35 specially prepared interrogatories or requests for admissions simply by attaching a Declaration of Necessity (pdf) pursuant to C.C.P. §2030.040 (pdf) and C.C.P. §2033.040 (pdf) stating the reasons why they...
I recently reviewed a case management order in a complex construction case venued in Southern California. The order required all parties to produce: Any and all relevant non-privileged and non-protected documents (consistent with California Evidence Code Section 250), including but...
Growing up in an Italian household, our dinners consisted of salad, pasta, wine and an argument. Afterwards we all went out for ice cream with no thoughts of the argument that took place at the dinner table. That is because we thought of arguments as a sport and there was no reason to hold any...