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

Alert Your Client to These Depo Issues

When preparing your client for his or her deposition, devote particular attention to explaining the following objectionable areas of inquiry and substantive law on those areas. Continue reading

The Do’s and Don’ts of Building Your Case with Social Media Info

The following is a guest blog post by Renee Galente Stackhouse. Renee is the founder and trial lawyer at Stackhouse, APC, where she focuses on plaintiff’s personal injury and military defense in San Diego. She is the immediate past President of California Women Lawyers, President of the CWL Foundation, Chair of the CLA SSF Section, and sits on the Board of the San Diego County Bar Association.

You would be surprised how easy it is to find public information on the Internet. Or maybe you wouldn’t, given the many stories of jobs lost and cases jeopardized by social media posts. Using Google and social media searches on parties and witnesses can be very helpful to your case, but make sure you don’t overstep. Continue reading

How to Write Special Interrogatories

woman drafting interrogatories on her computerDrafting special interrogatories is yet another mainstay of litigation practice that’s generally not covered well in law school. Consider this a summary overview to get you started. Continue reading

Do You Need a Discovery Referee?

It’s not feasible to stop a deposition every time an attorney or witness becomes obstructive, run to court to have a judge or discovery commissioner resolve the issue, and then resume the deposition. If you anticipate such problems, using a discovery referee may be a solution. Continue reading

Oops! What to Do When Privileged Material Is Inadvertently Produced

In the rush of document production, it’s always possible that privileged material will be inadvertently produced to the opposing party. What happens then? Is the privilege lost? Continue reading

This Is How Interrogatories and Depositions Compare

When deciding whether to use interrogatories or depositions in discovery, there are several things to compare. Continue reading