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Quoting Shakespeare
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 can’t understand...
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Don’t Get Intimidated and Play by the Rules
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...
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Am I Naïve to Think Something Should Be Done?
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...
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YOU NEED TO FILE A MOTION FOR A PROTECTIVE ORDER!!
Over lunch last week, a local attorney was complaining to me about his case that is going to trial in July. On the last day to serve written discovery, Plaintiff counsel had served each of his five...
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Acted with Substantial Justification
A fellow Bay Area attorney contacted me about being sanctioned in excess of $5,000. He was mortified, as it was the first time he had ever been sanctioned and couldn’t believe the amount he was...
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NEW YEARS RESOLUTIONS–Statutory Changes to the Discovery Act
As a new year of litigation begins, here are a few significant changes to the discovery statutes that you should be aware of: THE SEVEN-HOUR DEPOSITION Code of Civil Procedure §2025.290...
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Why You Need to Bring a Motion to Strike General Objections
Recently I was contacted to help on a party’s Motion to Compel Further Responses to Form Interrogatories, Requests for Production of Documents, and Requests for Admissions. In viewing opposing...
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A Third-Party Can Expect Sanctions for Ignoring a Subpoena for Electronically...
W. George Wailes, a Business Trial Attorney and Director at Carr McClellan, in Burlingame, CA brings us this warning from the California Court of Appeal about what could happen to a third party that...
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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...
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2015 New Years Resolutions–No real changes to the Discovery Act
I am happy to report that there were no substantive changes to the Discovery Act. The only change to any of the discovery codes is C.C.P. Section 2025.510 which involves deposition transcripts. As...
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The Interrogatory Says What it Says
There are very few discovery cases that come out each year. Usually they are are significant and involve privileges such as Coito v. Superior Court and Catalina Island Yacht Club v. Superior Court....
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Why You Need to Bring that Motion To Compel Further Responses to Interrogatories
The purpose of discovery is to take the “game” element out of trial preparation by enabling the parties to obtain evidence necessary to evaluate and resolve their dispute before a trial is necessary....
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Why You Need to Bring a Motion to Strike General Objections
Recently I was contacted to help on a party’s Motion to Compel Further Responses to Form Interrogatories, Requests for Production of Documents, and Requests for Admissions. In viewing opposing...
View ArticleClik here to view.
A Third-Party Can Expect Sanctions for Ignoring a Subpoena for Electronically...
W. George Wailes, a Business Trial Attorney and Director at Carr McClellan, in Burlingame, CA brings us this warning from the California Court of Appeal about what could happen to a third party that...
View ArticleClik here to view.
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...
View ArticleClik here to view.
2015 New Years Resolutions–No real changes to the Discovery Act
I am happy to report that there were no substantive changes to the Discovery Act. The only change to any of the discovery codes is C.C.P. Section 2025.510 which involves deposition transcripts. As...
View ArticleClik here to view.
The Interrogatory Says What it Says
There are very few discovery cases that come out each year. Usually they are are significant and involve privileges such as Coito v. Superior Court and Catalina Island Yacht Club v. Superior Court....
View Article
