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  • Motions to compel using CCP §§ 2031. 310 and 2031. 320.
    CCP § 2031 310 refers to orders compelling further response CCP § 2031 320 refers to orders compelling compliance Can I move for an order compelling BOTH within the same motion? In my case, on the one hand many of the party’s objections are without merit or too general, and on the other hand the party responded that they would comply with certain demands but did not In addition, these
  • Is an issue impliedly raised in a brief and at a hearing preserved on . . .
    I filed a motion to compel document production under CCP 2031 310 (a) (3) and the court ordered the other party to produce further documents However, the other party failed to fully obey the court’s order so I filed a motion under CCP 2031 310 (i) to enforce the order and sanction the other party The other party argued that I was trying to “further compel” and should be sanctioned
  • What are the rules in regard to Supplemental Request for Production of . . .
    First you should really hire a lawyer Who is the lawyer representing the plaintiff? You have 45 days to meet and confer and file a motion to compel further responses Supplemental responses are for them to update their responses You really need a lawyer who makes sure you have everything in your requests I handle collection defense cases on a regular basis Do you think you have a defense
  • CCP § 2031. 310. (a) (3) and objections which are without merit or too . . .
    CCP § 2031 310 (a) (3) and objections which are without merit or too general
  • What happens if a motion to compel is not accompanied by a meet and . . .
    The defendant in my case filed a motion to compel further responses to a request for documents There was some meet and confer before he filed it and the defendant put the meet and confer emails in his exhibits However, his motion was not accompanied by a meet and confer declaration as required by CCP § 2031 310 (b) (2) which states “The motion shall be accompanied by a meet and confer
  • Is a Verifcation to written discovery valid if it is not dated, but is . . .
    Before you file a motion to compel, you have to “meet and confer” with the other side, to attempt to resolve the problem informally See CCP secs 2016 040, 2030 300 (b), 2031 310 (b) (2) This need not be in person, but may be by telephone or email Email is preferable, because it creates a written record I believe that your time to file a motion to compel is running, because the other
  • Demand for Inspection of Premises? - Legal Answers - Avvo. com
    Demand for Inspection of Premises? Are the deadlines to object to a Demand for Inspection of Premises the same as let's say objecting to a deposition notice? 8 days mail and 3 personal service? If not what are the deadlines?
  • Time limit to file a motion to compel compliance under CCP § 2031. 320 . . .
    CCP § 2031 310 (c) states a 45 day limit for filing papers on a motion to compel further responses However, CCP § 2031 320 on motions to compel compliance with production does not state a time limit Why is that, and what is the time limit?
  • Any consequences for failure to stipulate to extension to 45 day rule . . .
    The responding party in my case has been stalling my informal efforts to resolve significant discovery issues and abuses and has played games by offering and falsely promising to stipulate to an extension to the 45 day limit within which to file a motion to compel If I have no option but to file the motion to compel without having been given an extension, can the responding party’s false
  • Meaning of “inadequate, incomplete, or evasive” responses in CCP § 2031 . . .
    Under CCP § 2031 310 (a) (2) a reason to compel further discovery responses is that “a representation of inability to comply is inadequate, incomplete, or evasive ” Is the meaning of “inadequate, incomplete, or evasive” broader than simply the form of the written responses? That is, can these terms also be used in relation to the facts of the case? For example, in my case my husband





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