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Proc., 2030.310 and 2031.310) You may be successful in obtaining them since you had to expend time and resources fighting over something to which you are entitled under the law. California: It is not relevant to this litigation nor reasonably calculated to lead to the discovery of admissible evidence [and to the extent it seeks information which does not concern events, conditions, or matters relating to the alleged actionable conduct underlying this lawsuit]. [3] It is overbroad in time and scope. [4] You need to know what is out there to defuse and counteract the impact it may have on your clients case. Vision. endstream endobj startxref This cookie is set by GDPR Cookie Consent plugin. Do not let this happen; review the discovery responses when received and timely meet and confer to obtain this very important information. Effective January 1, 2005. If defense plays games regarding these unprivileged documents, do not give in; you must file a motion to compel. For strategic reasons you may choose to answer the excessive discovery. There are some wonderful webinars and articles written by our colleagues about sub rosa discovery and strategies. This specification shall be in sufficient detail to permit the propounding party to locate and to identify, as readily as the responding party can, the documents from which the answer may be ascertained. Ass'n, Inc. v. Nationwide Mut. testing, or sampling is objectionable, the response shall contain a statement of compliance, In addition, one may object if the probative value of the request may be substantially outweighed by the expense of responding and the probability that the information will necessitate undue consumption of time and create a substantial danger of undue prejudice or of confusing the issues. endstream endobj 45 0 obj <>stream INFORMAL INFORMATION EXCHANGES One of the most effective ways to avoid discovery on discovery is to cooperate with opposing counsel and informally address discovery issues at the outset of the litigation during the FRCP 26(f) meet and confer process. (Glenfed Development Corp. v. Superior Court (1997) 53 Cal.App.4th 1113.). These objections are unmerited because plaintiffs do not have the burden under California law of obtaining a jury verdict over the underlying policy limits before being entitled to know what excess policies a defendant has that may potentially cover the losses.