Who Can Be Served with Interrogatories?

Interrogatories are powerful—they allow you to ask questions and then use the answers at trial. But you’re limited as to who you may serve with interrogatories. Here are the four main categories of who can be served with interrogatories. Continue reading

How to Get California Public Records

The usual discovery requests don’t always get you what you need. Sometimes you’ll do better seeking a public record under the California Public Records Act (Govt C §§6250–6276.48).  Continue reading

How to Control a Deposition Without Being Controlling

The attorney taking the deposition usually controls the proceedings. But the best way to take advantage of this control is to hold onto it loosely. Continue reading

6 Grounds for Objecting to Requests for Admission

A party may respond to an individual request for admission (RFA) by objecting to all or part of it. CCP §2033.230. The right to object is waived if not stated in a timely response, so it’s important to consider objections carefully. Here are the most common objections to RFAs. Continue reading

How Soon Can You Seek a Deposition?

Before you serve a deposition notice, make sure your timing complies with the statutes. Continue reading

Should You Amend Your Interrogatory Responses?

It’s not required that a party amend interrogatory responses to reflect information the party got after responding, but there are situations in which a party may want to do just that. Continue reading

What Constitutes a Good Faith Meet-and-Confer Effort?

Before filing a motion to compel discovery responses, the parties must engage in a “reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” CCP §2016.040. What constitutes a good faith meet-and-confer effort depends on a variety of factors. Continue reading

Keep This in Mind During Every Deposition

When taking or defending a deposition, always keep in mind that you’re making a record for the jury. Sometime later, perhaps years after the deposition took place, a jury may hear parts of the deposition and you want everything to be there and be clear. Continue reading

4 Key Documents in a Motion to Compel

A motion to compel must consist of at least four documents. Here’s a handy checklist to be sure that you’ve got all your motion papers set to go. Continue reading

New Year, New Laws for Civil Litigators

The California legislature has enacted new laws that may affect your litigation practice. Here are some of the key statutory changes you need to know about. Continue reading