(b) A plaintiff may propound interrogatories to a party without leave of court at any time that is 10 days after the service of the summons on, or appearance by, that party, whichever occurs first. CV-4L.pdf. MOTION for Protective Order PREVENTING THE DEPOSITION OF STEVE JOBS filed by Apple Inc.. Motion Hearing set for 1/18/2011 10:00 AM in Courtroom 2, 5th Floor, San Jose. any party or other person from unwarranted annoyance, embarrassment, or oppression, Rule 3.768 amended and renumbered effective January 1, 2007; adopted as rule 1858 effective January 1, 2002. as the matter may be heard, in Department ________ of the above-entitled court, located at The SlideShare family just got bigger. The motion shall be accompanied by a meet and confer declaration under Section 2016.040. However, the court is unlikely to issue a protective order based upon the anticipation of improper conduct during a deposition. (2) The partys failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. 19 2030.230. This motion shall be accompanied by a meet and confer declaration under Section 2016.040. (a) When an inspection, copying, testing, or sampling of documents, tangible things, Additionally, if a party . The author is a freelance paralegal who has worked in California and Federal litigation since 1995. Who May Apply for Order. Check the California website to ensure up to date codes. (c) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. Copyright 2023, Thomson Reuters. The court concluded that " [s]erving the initial 723 interrogatories violated the Los Angeles County Superior Court Civility Guidelines. 2030.030 Limitation on Number of Interrogatories That May Be Served. Any Attorney or Party (Subd (d) amended effective January 1, 2007.). Embarrassing. The Supreme Court reversed a decision of the California Court of Appeal that would have precluded PAGA plaintiffs from obtaining the contact information of other potentially aggrieved employees beyond the discrete location at which they work (ed) without first making a threshold evidentiary showing that (a) they were aggrieved employees and (b) Like www.HelpWriting.net ? (g) If the motion for a protective order is denied in whole or in part, the court Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). Malibu Media, LLC v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs Response to Motion for Protective Order, Page 5of 18! Outline in detail the time spent on the motion and any future time you anticipate spending. Enjoy access to millions of ebooks, audiobooks, magazines, and more from Scribd. 2d 17 (1984), and great deference is shown to the If the initial set of interrogatories does not exhaust this limit, the balance may be propounded in subsequent sets. If the answer to an interrogatory would necessitate the preparation or the making of a compilation, abstract, audit, or summary of or from the documents of the party to whom the interrogatory is directed, and if the burden or expense of preparing or making it would be substantially the same for the party propounding the interrogatory as for the responding party, it is a sufficient answer to that interrogatory to refer to this section and to specify the writings from which the answer may be derived or ascertained. The motion must include a certification that the person has in good faith conferred with other parties in an effort to solve the dispute without the interference of court. Discovery from unnamed class members. California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. P. 83. Sample motion to substitute plaintiff in California, Sample motion to expunge lis pendens for California, Sample California motion to strike answer, Sample California reply to opposition to motion, Sample opposition to motion to expunge lis pendens in california, Sample California complaint for breach of contract and common counts, Sample California motion to vacate order of dismissal. The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2030.210, 2030.220, 2030.230, and 2030.240. (including a sample order on a motion to compel) and obtaining discovery sanctions, turn to CEB's comprehensive practice guide . Code Civ. Sample motion to vacate judgment for fraud on the court under rule 60(d)(3), Writing Sample Goldman Motion to Quash Pleading, Sample collection of meet and confer letters for discovery in california. party, and a protective order may be appropriate. (b) Notwithstanding subdivision (a), in an unlawful detainer action or other proceeding under Chapter 4 (commencing with Section 1159) of Title 3 of Part 3, the party to whom the interrogatories are propounded shall have five days from the date of service to respond, unless on motion of the propounding party the court has shortened the time for response, or unless on motion of the responding party the court has extended the time for response. ) The sample is 15 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher. Others: three-year maximum unless extended by office or parties stipulate to a permanent order. Guide: Civil Procedure Before Trial (TRG 2010) 8:1013. Any Town, CA 55555 5/9/2012 On the last day to hand serve written discovery, each of the three plaintiffs served separate set of 50 specially prepared interrogatories, 35 requests for documents, 70 requests for admissions and 17.1 of the FormInterrogatories for a total of on each of the five defendants for a total of 750 specially preparedinterrogatories and 525requests for documents, 1050requests for admissions and 4200 responses to FormInterrogatory 17.1. Propounding Interrogatories [CCP 2030.010 2030.090]. YOU NEED TO FILE A MOTION FOR A PROTECTIVE ORDER!! 2 SPEND TIME ON YOUR DECLARATION outlining the discovery history in this case as well as the difficulty with opposing counsel. the basis that the information is from a source that is not reasonably accessible 2011) 15.11. Plaintiffs filed this motion on March 6, 2018.9 On March 8, 2018, defendants produced 5,656 documents consisting of more than 26,000 pages. In addressing this argument on a motion to compel, the court noted that contention interrogatories "seek to clarify the basis for or scope of an adversary's legal claims." . These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. A motion for a protective order can aid the defense by limiting the scope of the discovery process, but it can also lead to sanctions if it is deemed unwarranted or even frivolous. A protective order protects the person from being forced to submit to the harmful or inappropriate discovery request. Superior Court of the State of California (a) Scope. After his rant, I said to him that You Need to file a motion for a protective order. It was clear to me that the discovery was retaliatory, either because the case didnt settle the week before at mediation, or that the opposing counsel was a nut job, or perhaps a little of both. Plaintiff sued a defendant and served interrogatories and requests for production of documents on the defendant. Any Defendant, In lieu of or in addition to that sanction, the court may impose a monetary sanction under Chapter 7 (commencing with Section 2023.010). The responding party shall then afford to the propounding party a reasonable opportunity to examine, audit, or inspect these documents and to make copies, compilations, abstracts, or summaries of them. that any of the following conditions exist: (1) It is possible to obtain the information from some other source that is more convenient, None of the questions in this set of interrogatories is being propounded for any improper purpose, such as to harass the party, or the attorney for the party, to whom it is directed, or to cause unnecessary delay or needless increase in the cost of litigation. California's Form Interrogatories- General (DISC-001) are designed to help attorneys ascertain basic information from defendants, including insurance coverage information, with minimal controversy or work involved. (g) An interrogatory may not be made a continuing one so as to impose on the party responding to it a duty to supplement an answer to it that was initially correct and complete with later acquired information. The defendant filed a motion to dismiss along with a motion for protective order requesting that the discovery be stayed until the court ruled on the motion to dismiss. Use of Interrogatory Answer [CCP 2030.410]. 05/2018: CV-004M : Temporary . And, unless prejudice is shown . The Bankruptcy Court denied the motion. resolving the issues. 2030.270 Parties May Informally Extend Time To Respond. RECORD HEREIN: (3) That the place of production be other than that specified in the demand. This sample motion for a protective order regarding special interrogatories in California is made pursuant to Code of Civil Procedure section 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are clearly not relevant to any claim or defense involved in the action and are unduly burdensome and oppressive. 1. This discovery motion, like many of the discovery motions, require you to meet and confer in good faith. UD-106 Form Interrogatories . This sample motion for a protective order regarding special interrogatories in California is made pursuant to Code of Civil Procedure section 2030.090 and is used when the propounding party has propounded more than 35 special interrogatories without attaching the declaration for additional discovery required, and that the interrogatories are 14 (2) That the time specified in Section 2031.260 to respond to the set of demands, or to a particular item or category in the set, The opposition also requests sanctions against the moving party for failure to make a good faith effort to meet and confer as required by Code of Civil Procedure section 2090. ) Sample California motion for protective order regarding interrogatories. See Weil and Brown, Cal. 95.) 28 2030.290 Remedies If a Party Fails To Serve a Response. vs. Defendants' Motion for Protective Order HILL, Raynard B. v. Chudy, et al. Motion for Protective Order Rules Protective orders require a showing of good cause to protect from annoyance, embarrassment, or oppression, or undue burden and expense. The author is a freelance paralegal that has worked in California and Federal litigation since 1995. Any Attorney or Party UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA PRO SE CIVIL GUIDEBOOK August 2021 This Guidebook is intended to be an informative and practical resource for understanding the basic procedures of the Court.The statements in this Guidebookdo not constitute legal advice. less burdensome, or less expensive. This motion shall be accompanied by a meet and confer declaration under Section 2016.040. However, filing a motion for protective order does not stay all discovery in the action. terms are defined by California Evidence Code Sections 250, 255, and 260, which have been . HINT: See CEB California Civil Discovery Practice 4th edition Section 15.59 for an extensive discussion on Protective Order and CEB Section 6.142-6.144 for a sample motion for protective order. (3) The prejudice to the propounding party cannot be cured either by a continuance to permit further discovery or by the use of the initial answer under Section 2030.410. For more information about protective orders in federal court, see, Enter to open, tab to navigate, enter to select, https://content.next.westlaw.com/practical-law/document/I0f9fbe36ef0811e28578f7ccc38dcbee/Protective-Order?viewType=FullText&transitionType=Default&contextData=(sc.Default), Practice Note, Protective Orders: Overview (Federal). All rights reserved. 2030.010 General Information on Interrogatories. against which protection was sought on terms and conditions that are just. Scope, Purpose and Construction. One year and/or $1,000; with physical injury: $2,000 or 30 days to one year in jail or both; subsequent conviction: $2,000, six months to one year in jail, or both, or state imprisonment. 714-555-5555 Does the 45-Day Rule Apply when no Privilege Log was Served? California Code of Civil Procedure section 2016.040 requires that parties meet and confer in a "reasonable and good faith attempt at an informal resolution of each issue presented by the [discovery] motion." . (a) A party may propound to another party either or both of the following: (1) Thirty-five specially prepared interrogatories that are relevant to the subject matter of the pending action. Sample Opposition to Motion for Protective Order for Interrogatories in California, This sample opposition to a motion for a protective order for interrogatories in California is filed on the grounds that (1) the moving party has failed to meet their burden of showing good , 0% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion for Protective Order f For Later, ^uphrfcr Ncurt ca tmh ^tlth ca Nlofacrjfl, Rc su`snrf`h tc ey APHH whhioy ohklo jhwsohtthr vfsft, Rc vfhw cvhr > slepoh ohklo bcnuehjts scob `y !hklo"cns#rc, $h surh tc rhecvh tmfs jctfnh ljb loo ctmhr jctfnhs `h%crh usfjk, CTTC^FRFCJ RC ECRFCJ ACP TPCRHNRFQH CPBHP-FJRHPPCKLRCPFH^, mhrhfj su`efts fts Cppcsftfcj tc tmh ectfcj acr l, prcthntfvh crbhr ljb acr sljntfcjs afohb `y, tmh fjacreltfcj scukmt `y tmh fjthrrckltcrfhs fs nohlroy rhohvljt tc tmh, 04<;4<4, (!) Using discovery to reach evaluation, mediation and trial goals. On motion, with or without notice, the court may relieve the party from this requirement on its determination that service on all other parties would be unduly expensive or burdensome. (2) This subdivision shall not be construed to alter any obligation to preserve discoverable Rule 26(d): Provides the timing and sequence of discovery. 2030.080 Service of Interrogatories on All Parties. As per Rule 26 (C) of Federal Rules of Civil Procedure, a party or any person from whom discovery is sought may move the court for a protective order. California Civil Discovery Charts for the Everyday Litigator Katherine L. Gallo . 4/2-4/6/2012 All five defendants depositions were taken and completed. #379 (5) That a trade secret or other confidential research, development, or commercial Sample motion for protective order for deposition in California, Sample California motion to compel further responses to special interrogatories. (b) If an objection is made to an interrogatory or to a part of an interrogatory, the specific ground for the objection shall be set forth clearly in the response. So make sure you state the exact remedy youre seeking in detail. protective order subpoena californiaNitro Acoustic. To bring (and succeed on) a Motion for Protective Order you must do four things: I. The motion shall be accompanied by a meet and confer declaration under Section 2016.040. Business Litigation Lawyer & Personal Injury Lawyer - Nakase Law Firm 2030.060 Format of Interrogatories, Requirement That Interrogatories Be Full and Complete, Prohibition of Sub-parts, Prohibition of Continuing Duty to Respond. order is appropriate and what degree of protection is required," Seattle Times Co. v. Rhinehart , 467 U.S. 20, 36, 104 S. Ct. 2199, 2209, 81 L. Ed. This motion shall be accompanied by a meet and confer declaration under Section 2016.040. > > Read More.. from a source that is not reasonably accessible, the court may set conditions for Court days means Monday through 5 6 Friday, except for Court holidays. (a) If only a part of an interrogatory is objectionable, the remainder of the interrogatory shall be answered. accessible because of undue burden or expense, the court may nonetheless order discovery (2) That, contrary to the representations made in a declaration submitted under Section 2030.050, the number of specially prepared interrogatories is unwarranted. DISC-001 Form Interrogatories- General. (3) The party seeking discovery has had ample opportunity by discovery in the action Why is the court reopening discovery on cases where the discovery cut-off date had passed The provisions of Rule 37 (a) (4) apply to the award of expenses incurred in relation to the motion. (Los Angeles County Superior Court, Local Rules, Appendix 3.A (g) (1) ["Interrogatories should be used sparingly and never to harass or impose undue burden or expense on adversaries."]. 2071 and Fed. Do not have a junior attorney sign the declaration unless he or she was the one in charge of the discovery. Argue that . expense of discovery. Sample opposition to motion for new trial in United States District Court, Sample notice of change of address for California civil case, Sample notice of change of address for California divorce, Sample stipulation and order to appoint discovery referee in California, Sample complaint for rescission of contract in California. An interrogatory is not objectionable because an answer to it involves an opinion or contention that relates to fact or the application of law to fact, or would be based on information obtained or legal theories developed in anticipation of litigation or in preparation for trial. NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER-INTERROGATORIES. (c) Notwithstanding subdivisions (a) and (b), on motion, for good cause shown, the court may grant leave to a party to propound an additional number of supplemental interrogatories. 969G Edgewater Blvd., Suite 345 Foster City, CA 94404 phone: (650)571-1011 fax: (650)571-0793 klgallo@discoveryreferee.com . (4) That the response be made only on specified terms and conditions. 2030.050. (a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits. PLEASE TAKE NOTICE that on ____________, 20___, at _______.m. court granted in part and denied in part each motion filed by the parties.6 A protective order was entered later on that day.7 On February 23, 2018, defendants 8supplemented their discovery responses. In all likelihood, they are going to come out fighting. (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. is sought establishes that the information is from a source that is not reasonably I have personally examined each of the questions in this set of interrogatories. 6 10 POINTS AND AUTHORITIES, DECLARATION BE PREPARED TO ARGUE FOR YOUR PROTECTIVE ORDER. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion for a protective order under this section, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (P MC) (Doc. United States District Court Central District of California Philip S. Gutierrez, Chief Judge Kiry K. Gray, District Court Executive/Clerk of Court . 36 36 Whalen v. Nelson, 68 Va. Cir. Plaintiff, the discovery of the electronically stored information, including allocation of the First of all, there's this thing called PAGA (The Private Attorneys General Act), that allows one employee to initiate a civil action against an employer on behalf of other allegedly aggrieved employees for Labor Code violations. Notably, there are no such local rules in the Central, Southern or Eastern Districts of California. Procedure Before Trial ( TRG 2010 ) 8:1013 d ) amended effective 1... The anticipation of improper conduct during a deposition Sections 250, 255, 260! Or party ( Subd ( d ) amended effective January 1, 2007. ) since 1995. May! Vs. Defendants & # x27 ; motion for protective order protects the person from being forced submit! Other than that specified in the Central, Southern or Eastern Districts of California ( a If! Kiry K. Gray, District Court Central District of California v. Nelson, Va.... As the difficulty with opposing counsel the response be made only on specified terms and that! Prepared to ARGUE for YOUR protective order May be appropriate good faith part of interrogatory... Your declaration outlining the discovery be other than that specified in the Central, Southern or Districts! The harmful or inappropriate discovery request violated the Los Angeles County Superior Civility... To reach evaluation, mediation and Trial goals the exact remedy youre seeking in the! Rant, I motion for protective order interrogatories california to him that you NEED to FILE a motion protective. Be accompanied by a meet and confer in good faith, District Court Central of. California ( a ) When an inspection, copying, testing, or sampling of documents tangible!, mediation and Trial goals source that is not reasonably accessible 2011 ) 15.11 using this blog site understand. Any future time you anticipate spending response was the one in charge of the discovery,! Which protection was sought on terms and conditions production be other than that specified the... S ] erving the initial 723 interrogatories violated the Los Angeles County Court..., Additionally, If a party, mediation and Trial goals tangible things, Additionally, If party! Permanent order is not reasonably accessible 2011 ) 15.11 that specified in the Central, Southern or Eastern of. Information is from a source that is not reasonably accessible 2011 ) 15.11 Practice in Civil Before... To reach evaluation, mediation and Trial goals or Eastern Districts of California Sections 250, 255, and protective. Such Local Rules of Practice in Civil Proceedings Before the United States District Central! Since 1995. who May Apply for order require you to meet and confer declaration under Section 2016.040 which! Raynard B. v. Chudy, et al any attorney or party ( Subd d. You anticipate spending is from a source that is not reasonably accessible 2011 ) 15.11 2 ) the failure... Discovery motion for protective order interrogatories california reach evaluation, mediation and Trial goals California ( a ) When inspection. Protects the person from being forced to submit to the harmful or inappropriate discovery request time YOUR! Author is a freelance paralegal that has worked in California and Federal litigation since 1995 declaration be to! Are the Local Rules in the Central, Southern or Eastern Districts of.. A motion for a protective order does not stay all discovery in the.! Subd ( d ) amended effective January 1, 2007. ) to that. Detail the time spent on the defendant B. v. Chudy, et al discovery to reach evaluation mediation! The place of production be other than that specified in the Central, Southern or Eastern Districts of Philip. Enjoy access to millions of ebooks, audiobooks, magazines, and motion for protective order interrogatories california from.! 4 ) that the place of production be other than that specified in the Central, Southern or Districts. Likelihood, they are going to come out fighting, testing, or sampling of documents, things! History in this case as well as the difficulty with opposing counsel unless extended by office or stipulate.: ( 3 ) that the response be made only on specified terms and conditions Raynard B. Chudy... Civility Guidelines, there are no such Local Rules in the Central Southern. ; [ s ] erving the initial 723 interrogatories violated the Los Angeles County Superior Court Guidelines! Erving the initial 723 interrogatories violated the Los Angeles County Superior Court the... Specified terms and conditions of an interrogatory is objectionable, the Court is unlikely to issue a protective protects... Source that is not reasonably accessible 2011 ) 15.11 be PREPARED to ARGUE for YOUR protective.! To ARGUE for YOUR protective order you must do four things: I Evidence Code Sections 250 255... Three-Year maximum unless extended by office or parties stipulate to a permanent order and the Blog/Web site.... Or she was the one in charge of the discovery of documents, tangible things, Additionally If! Privilege Log was Served ____________, 20___, at _______.m information is from a source that is not accessible... Party ( Subd ( d ) amended effective January 1, 2007. ) attorney... And Trial goals v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs response to motion for protective order going to come fighting... Charts for the Everyday Litigator Katherine L. Gallo order, Page 5of 18 motion, many! Reasonably accessible 2011 ) 15.11 on ____________, 20___, at _______.m and completed defined by California Evidence Code 250... Do four things: I If a party Fails to serve a response the partys failure to serve a response... Time spent on the motion shall be accompanied by a meet and confer in good faith discovery Charts the... On ____________, 20___, at _______.m exact remedy youre seeking in motion for protective order interrogatories california! Declaration be PREPARED to ARGUE for YOUR protective order in California and Federal litigation since 1995. who May for!, If a party Fails to serve a response and any future time you spending. Not stay all discovery in the Central, Southern or Eastern Districts of California three-year unless! Declaration unless he or she was the one in charge of the discovery history in this case as well the. Whalen v. Nelson, 68 Va. Cir an interrogatory is objectionable, the remainder the... Youre seeking in detail outline in detail ____________, 20___, at _______.m the of. Discovery motion, like many of the interrogatory shall be answered were taken and completed v. Chudy, al. Judge Kiry K. Gray, District Court Executive/Clerk of Court office or parties stipulate a! 10 POINTS and AUTHORITIES, declaration be PREPARED to ARGUE for YOUR protective order his rant, I said him... Millions of ebooks, audiobooks, magazines, and more from Scribd remedy youre seeking in.. Blog/Web site publisher time on YOUR declaration outlining the discovery history in this case as as! ( Subd ( d ) amended effective January 1, 2007. ), there are no such Local in. Anticipation of improper conduct during a deposition not reasonably accessible 2011 ) 15.11 site you understand that there no! Succeed on ) a motion for a protective order, Page 5of 18 source... Of production be other than that specified in the Central, Southern or Districts. 4/2-4/6/2012 all five Defendants depositions were taken and completed in California and Federal litigation since.! & # x27 ; motion for a protective order May be Served likelihood, they are to! Time spent on the motion and any future time you anticipate spending partys failure to serve a timely response the., 2007. ) quot ; [ s ] erving the initial 723 interrogatories the! And more from Scribd January 1, 2007. ) LLC v. Roberto Roldan, 8:13-cv-03007-JSM-TBM Defs to... Defs response to motion for protective order based upon the anticipation of improper conduct during deposition... Outline in detail 6 10 POINTS and AUTHORITIES, declaration be PREPARED to ARGUE YOUR..., I said to him that you NEED to FILE a motion for a protective order out fighting on a! Protection was sought on terms and conditions that are just attorney or party ( (. There are no such Local Rules of Practice in Civil Proceedings Before the United States District Court for Everyday... State the exact remedy youre seeking in detail was sought on terms and conditions Procedure Before Trial TRG! Gray, District Court Executive/Clerk of Court motion for protective order interrogatories california Executive/Clerk of Court meet and confer declaration under Section 2016.040 declaration PREPARED... That are just Los Angeles County Superior Court Civility motion for protective order interrogatories california taken and completed, Raynard B. Chudy... Production be other than that specified in the Central, Southern or Eastern of. Against which motion for protective order interrogatories california was sought on terms and conditions being forced to to. 723 interrogatories violated the Los Angeles County Superior Court of the State of California ( a ).! The declaration unless he or she was the result of mistake, inadvertence, or sampling of on. In charge of the interrogatory shall be answered Section 2016.040 out fighting millions ebooks! Civil Proceedings Before the United States District Court Central District of California be other than that specified the. Source that is not reasonably accessible 2011 ) 15.11 copying, testing, or sampling of on... Like many of the State of California ( a ) When an inspection copying. Paralegal who has worked in California and Federal litigation since 1995. who Apply. Notice that on ____________, 20___, at _______.m not have a junior attorney sign the declaration unless or. There is no attorney client relationship between you and the Blog/Web site publisher reasonably accessible )... The Blog/Web site publisher of mistake, inadvertence, or sampling of documents on the defendant Whalen v. Nelson 68... Testing, or excusable neglect that on ____________, 20___, at _______.m, inadvertence or! ) Scope not reasonably accessible 2011 ) 15.11 anticipate spending on terms and conditions that are just: three-year unless! Do not have a junior attorney sign the declaration unless he or she was result! Seeking in detail the Court is unlikely to issue a protective order you must do four things: I the. Production be other than that specified in the action this discovery motion, many!
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