Douglas Robbins, a twenty year trial attorney and fellow Discovery Referee, published his “California Discovery Manual for 2026,” which is one of the “go to” discovery treatises you should have on your desk. I found his privacy analysis regarding
One of the often used garbage objections in response to written discovery, especially in document demands, is the phrase “vague, ambiguous unwarranted annoyance, embarrassment, and oppression and undue burden and expense.” Which is a paraphrase of Code of Civil Procedure §2023.010(c)
How often do you see this objection? Irrelevancy is one of the garbage objections that parties throw out in response to discovery. Do you wonder if opposing counsel actually understands what is relevant in discovery? Did you ever question if opposing counsel
Over the years, I have heard numerous motions for issue, evidence and terminating sanctions. I found that it is difficult to rule on motions for issue and evidence sanctions if the Separate Statement is not complete. If the Separate Statement does not
Having reviewed thousands of Motions to Compel Further Responses over the years, I rely heavily on the separate statement filed with these motions. Unfortunately, I find that many of the separate statements are deficient and not in compliance with Rule
Most discovery disputes involve requests for production of documents. This is because there are specific requirements for a party to properly respond to the request which has been the subject of many of my blogs, including a responding party’s obligation to
California law expressly provides for discovery of information about the evidence and contents of any insurance agreement under which a carrier may be liable to satisfy all or part of a potential judgement or to indemnify or reimburse payments made
In the case of City of L.A. v. PricewaterhouseCoopers, LLC (2024) 17 C5th 46 the California Supreme Court unanimously held that the Discovery Act gives courts independent authority to impose sanctions for discovery abuses and patterns of discovery abuse provisions.
We all have been doing Zoom depositions for the last four years. As we have limped along, we have developed implied rules and protocols for having these depositions, but there are no written rules or guidance on how these depositions should
I recently received an inquiry regarding Code of Civil Procedure section 2023.050, which now states that the court SHALL impose sanctions of $1000 payable to the requesting party regarding requests for production of documents in deposition notices or document demands. These were