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

Before Requesting Discovery, Have a Plan to Enforce It

When starting discovery, your focus is on the specific requests you will make. But don’t forget to have a plan to enforce your discovery efforts. Continue reading