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
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
Once discovery starts, you’ll need to contact your client to help with responses. Here’s a sample letter to explain what is happening and what you need from your client. Continue reading
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
The other side is not giving you adequate discovery responses. In frustration, you may want to file a motion to compel. But stay calm and consider carefully whether doing so really makes sense and if there are better alternatives. Continue reading
Many attorneys mistakenly believe that answers to interrogatories and requests for admission are automatically in evidence after they’re lodged with the court. Not so! First, you’ve got to formally introduce them into evidence.