This discovery motion, like many of the discovery motions, require you to meet and confer in good faith. Responding to Interrogatories [CCP 2030.210 2030.310]. I am propounding to __________ the attached set of interrogatories. motion for a protective order. (a) The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any of the following: (1) An answer containing the information sought to be discovered. See C. In this instance, the order is necessary to prevent a partys serving voluminous, unfocused discovery on the eve of trial. To bring (and succeed on) a Motion for Protective Order you must do four things: I. produced or made available at all. 228976) BROWNSTEIN HYATT FARBER SCHRECK, LLP 21 East Carrillo Street Santa Barbara, California 93101 Telephone No: (805) 963-7000 Facsimile No: (805) 965-4333 (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) 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. shall not impose sanctions on a party or any attorney of a party for failure to provide with substantial justification or that other circumstances make the imposition of RECORD HEREIN: (2) This subdivision shall not be construed to alter any obligation to preserve discoverable 27 The Bankruptcy Court denied the motion. 26 Feb Feb The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. and conditions. Thus, a motion for protective order should be denied if it wasn't file within the 30-days to respond. Case No. 2030.290 Remedies If a Party Fails To Serve a Response. 12 Plaintiff also filed a Motion to Compel Production of Joint Defense Agreements from Defendants, (P MC: JDA) (Doc. (6) That a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a certain way. terms are defined by California Evidence Code Sections 250, 255, and 260, which have been . DISC-002 Form Interrogatories- Employment Law. Motion Calendar; Post Indictment Arraignment (PIA) Magistrate Judge Criminal Duty . 4. (a) The interrogatories and the response thereto shall not be filed with the court. The sample is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. file a motion for protective order pursuant to Code of Civil Procedure 2019.030 and 2030.090. (c) The court shall grant a motion under subdivision (b) if it determines that all of the following conditions are satisfied: (1) The initial failure of the responding party to answer the interrogatory correctly has substantially prejudiced the party who propounded the interrogatory. If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient answer to that interrogatory to refer to this section and to specify the writings from which the answer may be derived or ascertained. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion for a protective order under this section, 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. Papers that do not conform with the requirements will be rejected by the filing clerk. No. Finally, describe your meet and confer with opposing counsel. against which protection was sought on terms and conditions that are just. This motion shall be accompanied by a meet and confer declaration under Section 2016.040. 4/2-4/6/2012 All five defendants depositions were taken and completed. The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2030.210, 2030.220, 2030.230, and 2030.240. Tap here to review the details. Th%s

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