8 by Julie A. Goren | Jan 15, 2022 | Articles. 1955)). The Court must impose sanctions, with ..its memorandum of points and authorities, supported its request for monetary sanctions with a misrepresentation of the law to the Court. (Winter v. Window Fashions Professions, Inc. (2008) 166 Cal.App.4th 943, 947. A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. B to Def. TRC additionally cites to Code of Civil Procedu Driveatron, L.L.C. try clicking the minimize button instead. Proof of Service Filed - Ntc of Motion and Motion to Compel Deposition att, CHAVARRIA ROURK V NISSAN NORTH AMERICA Print, Order Filed Re: - ORDER TO COMPEL DEPOSITION OF DEFENDANT EVELYN SHEPERD F, Motion to Compel Further Responses to Interrogatories, Motion to Compel Discovery Responses (CCP 2030.300), Motion to Compel Responses to Request for Production of Documents, Motion to Compel Further Responses to Special Interrogatories, Motion to Compel Deposition of Person Most Qualified (PMQ), Stafford v. Avenal Community Health Center. If one party to a case has filed a motion with the court, the other side can file an opposition. An opposition is a written statement explaining to the judge why the other side is not entitled to whatever he is asking for in his motion. The failure of a claimant to comply with this subdivision is a waiver of the claimants right to compel arbitration. (Code Civ. As Plaintiff previously noted in its Motion to Compel, Defendant's steadfast insistence on the irrelevance of evidence from around the time of the filing of the complaint is inconsistent with the Court's Order granting Plaintiff's Motion to Supplement its Opposition to Defendant's Motion to Dismiss with information from 2001 and 2002. 6 Rule 3.740 Collections$10,000.01 - $25,000 Limited, 1 The rules governing the doctrine of substantial compliance are well settled. (Robertson v. Health Net of California, Inc. (2005) 132 Cal.App.4th 1419, 1430). As Plaintiff explained in its Motion to Compel, the relevant time period for purposes of establishing jurisdiction in this case is the date the complaint was filed. Your subscription has successfully been upgraded. Plaintiff still seeks to depose Mr. Seely, President of Gwaltney of Smithfield, Ltd., one of the Smithfield subsidiaries doing business in the District of Columbia, as well. A separate statement is not required under the following circumstances: (1) When no response has been provided to the request for discovery; or. Between November 2001 and the present, that number has increased by another 50 percent (from approximately 100 to 150), with a current payroll of approximately hbbd```b``1Wdd L ,f`r\&uIYf$s@ v'6H,bo` when new changes related to " are available. ), Within 30 days after service of the summons and complaint, the claimant shall file and serve a motion and notice of motion pursuant to Section 1281.4 to stay the action pending the arbitration of any issue, question, or dispute that is claimed to be arbitrable under the agreement and that is relevant to the action to enforce the claim of lien. Plaintiff's Memorandum of Points and Authorities in Support of its Motion to Compel ("Pl. A motion to compel responses or documents at a deposition must be made no later than 60 days after completion of the record which is when the court reporter signs the transcript. How long does a plaintiff have to respond to an answer? v. Law Offices of George L. Young, et al. 2030.290 (a). (Cal. The purpose of a motion to compel under the Federal Rules of Procedure is to compel a response if a party fails to respond that inspection will be permittedor fails to permit Auto. Which Teeth Are Normally Considered Anodontia? CHARGE (RISC). Meet and confer: A prerequisite to bringing a motion to compel further responses is a reasonable and good faith attempt to informally resolve the issues presented by the motion. TimesMojo is a social question-and-answer website where you can get all the answers to your questions. Now, assuming you find all of the applicable codes and rules for this early part of the process, it is not enough to simply read them. Once the identity and description of the withheld items are known, a determination whether to compel the items can be made. Case No. The State and Federal Rules of Civil Procedure require parties to meet and confer before bringing a motion to compel. This is a petition to compel arbitr ..ndents filed an Opposition on July 19, 2019. separate filing fees; subsequent Motions in same action: $25.00. 11. Motion to Enforce Settlement: $25.00, but may be shifted to other Party by judge. 12. Motion to Compel: Rule 26, SCRCP: $25.00, but may be shifted to other Party by judge. 13. Rule 40, SCRCP a. (a): Request for Jury or Non-Jury in Pleadings: No Charge. b. It presently permits a defendant to be tried in absentia only in non-capital cases where the defendant has voluntarily absented himself after the trial has begun. at 12.) You have to know how to count to that 45th day, what to do if that day lands on a holiday or weekend, and, where the responses were not personally served, how many days by which to extend that 45-day deadline. Last. Website Copyright 2023 by Neubauer & Associates, Inc.The articles appearing in In fact, searching for older documents would seem to be more difficult than finding more recent ones. No fee is required to file an opposition. 1. (Theres a $15 off Coupon Code at the bottom of the page.). : BC577644 (Motion to Compel at 4). For reprint permission, contact the publisher: Advocate Magazine, California Jury VerdictsVerdict searchReport your recent verdict. On March 30, 2022, the Secretary filed his Reply to Respondents Opposition to Motion to Compel Entry upon Land (Reply). By _______________/s/________________ Nina B. Hale Jessica K. Delbaum Alexander Hewes, Jr. D.C. Bar No. (1) To grant the motion to compel plaintiff to submit to further deposition and to provide further responses to all deposition questions specified in the separate statement of disputed responses filed by defendant on September 21, 2018. Petitioner Stephen Warnes Motion to Compel Arbitration is DENIED. by the author. Drafting, filing, and serving a motion to compel further responses and calendaring all associated deadlines demands strict compliance with scores of requirements. Fox Rothschild LLP (Fox), by undersigned counsel, files this memorandum in opposition to the Receivers. Rule 66: Everything has a fandom, everything. Poulson, Executive Vice President, General Counsel, and Senior Advisor to the Chairman, discussed Smithfield's acquisition of IBP, work in Manhattan. 12cC.C.P. MOVING PARTY: Plaintiff Rand Semaan Proc.. 2025.480(b).) BACKGROUND: Plaintiff or Defendant, In Pro Per DECLARATION OF DECLARANT'S NAME I, Declarant's Name, am the Plaintiff or Defendant in this matter, and I declare the following in support of my Proc., 1281.4. the discovery matters at issue in defendants Motion . Motions to Compel If a party doesnt respond to interrogatories or requests for production, then the party seeking those answers must file a motion to compel with the court. These codes and rules dictate format, content, and deadlines. when new changes related to " are available. opposition to motion to compel california (1) The court may rule on a motion at any time after an opposition or other response is filed or the time to oppose has expired. bTheres a rule for everything in California State Court civil litigation. Act in good Faith. . The court declined to go with them. Consequences of Refusing to Provide Evidence Requested in a Motion to Compel. County of Los Angeles Jensen v. Vision Care Center, a Medical Group, Inc. Reply to Opposition to Motion to Compel Arbitration Filed - Filing May 24, 2021. and C.R.C. ), A petition to compel arbitration is in essence a suit in equity to compel specific performance of a contract. Plaintiff merely seeks to compel production of documents and answers to interrogatories that were part of Plaintiff's original requests, and is not seeking any "additional" documentary or written discovery as Defendant complains. See Shapiro, Lifschitz & Schram, P.C. It is far from evident why producing documents preceding the accrual of the cause of action was less burdensome for Defendant than producing documents following the periods of the alleged wrongdoing;(5) the older documents are certainly less relevant. Defendant selectively quotes MCI. This could vary from two court days to five calendar days to ten calendar days, depending upon the service method and, when served by mail, the location of the parties. Memo") at 132:23-133:24, 6:18-21; Ex. EMMY NOMINATIONS 2022: Outstanding Limited Or Anthology Series, EMMY NOMINATIONS 2022: Outstanding Lead Actress In A Comedy Series, EMMY NOMINATIONS 2022: Outstanding Supporting Actor In A Comedy Series, EMMY NOMINATIONS 2022: Outstanding Lead Actress In A Limited Or Anthology Series Or Movie, EMMY NOMINATIONS 2022: Outstanding Lead Actor In A Limited Or Anthology Series Or Movie. Defendant asserts that Plaintiff has deposed six witnesses and that Smithfield has produced over 9,000 pages of documents. [TENTATIVE] RULING RE: 30-2014-00734190-CU-MC-CJC Plaintiff/Petitioner, REPLY TO DEFENDANTS OPPOSITION TO POST-DISCHARGE V. RECEIVERS MOTION FOR (Richardson Reply Decl., Ex. relies on Litigation By The Numbers (LBTN), the essential California civil practice guide updated twice yearly. (Id. Optional Reply: five court days before the hearing date. procedural history Needless to say, Plaintiff has been conducting discovery of Smithfield's relationships with its various subsidiaries doing business in this District only since the Court ordered it on May 12, 2003. Def. Adding your team is easy in the "Manage Company Users" tab. Plaintiff contends that Defendant has breached an agreement to provide ..ity Company dba DAT moves to compel discovery responses, for an order deeming admissions admitted, and for monetary sanctions. (Mendez v. Mid- Wilshire Health Care Center (2013) 220 Cal.App.4th 534. (Hyundai Amco Am., Inc. v. S3H, Inc. (2014) 232 Cal.App.4th 572, 574. STEPHEN WARNE; Petitioner, vs. YORK RISK SERVICES, et al. will be able to access it on trellis. (Code Civ. Def. Make at least one copy MOTION TO COMPEL DISCOVERY RESPONSES, FOR AN ORDER DEEMING ADMISSIONS ADMITTED, AND FOR MONETARY SANCTIONS 1. With respect to the merits, most of the key witnesses are in Manhattan. When a party to whom interrogatories are directed fails to respond, under CCP 2030.290(b) a party propounding the interrogatories may move for an order compelling a response. This article discusses the civil codes and court decisions on filing motions to compel and dealing with privilege objections. PLAINTIFFS MEMORANDUM (CCP 2025.450(a).) 3 Your subscription has successfully been upgraded. ), An objection to a deposition question does not excuse the deponent from the duty to answer unless the objecting party demands the deposition be suspended to allow for the filing of a motion for protective order. A single attempt to meet-and-confer does not show very much professional courtesy, and will not generate much favor with the court. (Wellpoint Health Networks, Inc. v. Sup. Your subscription was successfully upgraded. Grounds exist for rescission of the agreement. There is no single determinative test of waiver, and the question for the trial court is one of fact. (Guess?, Inc. v. Sup. 5 Before the Cross-Complaint was filed, Erazo filed a Petition to Compel Arbitration (the Petition) on September 14, seeking an order compelling LAFCU to submit to arbitration for the controversy alleged in the Complaint. Please wait a moment while we load this page. LEXIS 10549, (D.D.C. Material must not be incorporated into the separate statement by reference. Posted on Aug 1, 2012. (2) Defendants Motion to Compel Deposition of Julio Id. On February 13, 2019, Plaintiff JOse Ojeda, et al., Plaintiff, v. Michelle Elizabeth Bargnas, et al., Defendants. Frank W. Chen has been licensed to practice law in California since 1988. How To Draft A Successful Motion To Compel. admitted request for admissions (set one) as to cross-complainant Marc Brock is MOOT. These codes, rules, and forms change often! ; Defendants. Beneath the conclusion, add the words Respectfully Submitted and then insert a signature block underneath. [This, too, is covered in LBTN. Perpetuating testimony is the procedure permitted by both federal and California discovery rules for preserving the attestation of a witness that might otherwise be lost prior to the trial in which it is intended to be used. by clicking the Inbox on the top right hand corner. Part 2 Part 2 of 4: Drafting Your Opposition Motion Download ArticleFormat the document. To formally oppose the motion in limine, you need to draft your own motion in opposition.Add the caption information. The caption includes the name of the court, as well as the parties names and the case number.Insert an introduction. Make your argument. Add a conclusion. Sign your motion. Create a certificate of service. Testimony from Mr. Trub, Defendant's CFO in the 1998 - 1999 time frame, is still necessary, however, particularly given Defendant's continued insistence that the temporal inquiry for jurisdictional purposes is the time of the cause of action, rather than the time of the filing of the complaint. (Code Civ. Last. Courts routinely look to the activities of subsidiaries that have nothing to do with the subject matter of the litigation. RESPONDING PARTY(S): No opposition filed. Ma Laboratories, Inc., et al. . 115 (N.D. Ill. 1990), 8 C. Wright & A. Miller, Federal Practice and Procedure 2007 (2d ed. If the last day falls on a day that the court is closed, you have until the next day that the court is open. A motion to compel can be filed against an opposing party for the failure to respond to discovery requests or if the response is insufficient. It is good practice to have multiple meet-and-confer attempts, both written and over the phone. STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: June 5, 2003), Frederick Cinema Corp. v. Interstate Theatres Corp., 413 F. Supp. will be able to access it on trellis. 29 C.F.R. (Code Civ. Adding your team is easy in the "Manage Company Users" tab. 1983), Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340 (1978), Shapiro, Lifschitz & Schram, P.C. Under Code of Civil Procedure section 1281.2, ), Once petitioners allege that an arbitration agreement exists, the burden shifts to respondents to prove the falsity of the purported agreement, and no evidence or authentication is required to find the arbitration agreement exists. The role of the trial court is to sit as a trier of fact, weighing any affidavits, declarations, and other documentary evidence, together with oral testimony received at the courts discretion, to reach a determination on the issue of arbitrability. (Hotels Nev. v. L.A. Pac. 6 to Pl. A privilege log must sufficiently specify each document being withheld so it can be determined whether or not it is in fact privileged. To determine when the opposition is due, start at the hearing date and count backward in time. Sharon Melinda Kwan, et al. LEXIS 10549 (D.D.C. 's Opp. defendantS motion for order compelling plaintiffs attendance and testimony at deposition ), If a motion under subdivision (a) is granted, the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code of Civ. See also Declaration of Katherine A. Meyer, Exhibit 1 to Plaintiffs Opposition to Defendants Motion to Compel Discovery From Plaintiff STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS: Simply stated, Plaintiff seeks only to conduct the discovery the Court granted. Plaintiff's jurisdictional discovery requests are narrowly tailored to produce information relevant to the issues raised by Defendant in its Motion to Dismiss. The court shall not order the parties to arbitrate if the court determines that, Waiver of the right to arbitration does not occur by mere participation in litigation. [A]s an abstract exercise in logic it may appear that it is inconsistent for a party to participate in a lawsuit for breach of a contract, and later to ask the court to stay that litigation pending arbitration. 3 Plaintiff was therefore compelled to request information encompassing both Defendant's asserted relevant time period and the time period Plaintiff asserted was most relevant, i.e., the time the complaint was filed. Those related to calculating deadlines interrelate and must be applied in the right order. Filing motions to compel to obtain seemingly unimportant discovery will not help win the war. ), (d) Identification of interrogatories, demands, or requests. Between November 2001 and the present, that number has increased by another 50 percent (from approximately 100 to 150), with a current payroll of approximately, Defendant Has Rejected Plaintiff's Offers to Ease the Claimed Burden of Discovery. at 14:8-14. I. Christine Raos Motion to Compel Deposition of Super Talent Electronics, Inc. and Great World Real Estate, LLC, and for Sanctions is GRANTED. Id. Lexis 25073 (D.D.C. Proc., 2025.450(g)(1). Replies must be filed no later than 5 days before the hearing. Department 78 2030.300Govt. Yes, you can file a motion for sanctions and cite which rule opposing counsel is breaking. BizAttorney : Motion For Sanctions will be the title in the caption, you will state the facts that support your argument. A motion to compel can be filed against an opposing party for the failure to respond to discovery requests or if the response is insufficient. A misstep at any point may result in denial of the motion and a waiver of the right to compel further responses. Is a motion to compel a pleading or discovery? v. eWiz Express Corporation, et al. DEFENDANTS RESPONSE IN OPPOSITION TO PLAINTIFFS MOTION TO COMPEL INTRODUCTION The question presented by Plaintiffs motion is a simple one: is providing basic information about state Universities diversity, equity, and inclusion (DEI) programs, as directed by the Governors December 28, 2022 Memorandum, a step You will lose the information in your envelope, Order Filed Re: - Plaintiff's Motion to Compel Initial Responses to Discov, Order Filed Re: - ORDER ON MOTION TO COMPEL INITIAL RESPONSES FILED (IMAGE, Order Filed Re: - ORDER RE MOTION TO COMPEL INITIAL RESPONSES TO DISCOVERY, Miscellaneous Document Filed - ORDER RE MOTION TO COMPEL INITIAL RESPONSES, Motion filed - Motion to Compel Initial Responses, Reply to Opposition to Motion to Compel Initial Responses Filed - Filing, Northern California Collection Service, Inc. VS Bhandari, Notice of Motion to Compel Initial Responses, Opposition to Motion TO COMPEL INITIAL RESPONSES - Opposition to Motion, 6/2/2022-Proposed Order Re: Motion to Compel Initial Responses-Hrg: 6/28/2, Mark Jackson vs. United Health Centers of the San Joaquin Valley, 6/2/2022-Notice of Motion to Compel Initial Responses to Discovery (x3)-Hr, Blanca Perez vs. United Health Centers of the San Joaquin Valley, Motion to Compel Further Responses to Interrogatories, Motion to Compel Discovery Responses (CCP 2030.300), Motion to Compel Responses to Request for Production of Documents, Motion to Compel Further Responses to Special Interrogatories, Motion to Compel Deposition of Person Most Qualified (PMQ), SHARON MELINDA KWAN ET AL VS LAW OFFICES OF GEORGE L YOUNG A. Marilyn Hughes, in pro per. (Complaint, 11.) 840, 845 (D.D.C. Def. If sanctions are sought, the motion to compel must set forth the authority for sanctions and be accompanied by a declaration detailing the type and/or amount of the sanctions. [LBTN has an entire chapter devoted to Filing, Service, and Calendaring. It includes detailed information about each method of service, when they are authorized, the various extensions of time, and detailed instructions on calculating deadlines. A motion to compel asks the court to order either the opposing party or a third party to take some action. ), If a motion seeks to order the deponent to produce documents listed in the deposition notice, then the motion must set forth specific facts showing good cause justifying the production for inspection of any document, electrically stored information, or tangible thing described in the deposition notice. (Code Civ. Further, Smithfield's assertion that Plaintiff asks for information on 35 subsidiaries fails to mention that Plaintiff only seeks documents and information on subsidiaries that transact business in the District of Columbia, not all Smithfield subsidiaries. Any reply brief must be served and filed within two court days of service of the opposition papers and may be no longer than 5 pages. The motion must be filed and served 16 court days before the hearing (add 5 days for mail or 2 days for FedEx). Accessing Verdicts requires a change to your plan. 6 GM filed an Answer on June 6, 2018. The motion must be filed and served at least 16 court days prior to the hearing. Ct. (1980) 111 Cal.App 3d 902, 905-06. (1) A judge may require that if any authority other than California cases, statutes, constitutional provisions, or state or local rules is cited, a copy of the authority must be lodged with the Even so, as detailed in its Motion to Compel, Plaintiff offered on several occasions to address Defendant's burden claims while ensuring access to information to which it is entitled. (Code Civ. Having been designated confidential pursuant to the Stipulated Protective Order, the exhibits were filed under seal. Opposition papers must be filed no later than 9 court days before the hearing date. Defendant's Opposition provides selective quotations from deposition testimony intended to show the autonomy of its subsidiaries. It is good practice to review local rules before filing a motion to compel. ), The party moving to compel arbitration must establish that it demanded arbitration from the other party, and that the other party refused to agree to arbitration. Court finds that the reasonable amount of attorneys fees and costs directly related to the instant motion is a total amount of $1,060, to be issued against Defendant 10. Despite Defendant's unilateral limitation on discovery of the post-January 31, 2001 period, Plaintiff has learned that Smithfield's influence and control over its subsidiaries has increased in recent years: Defendant claims Plaintiff's discovery requests are unduly burdensome because they reach beyond the "relevant" time period. A single procedure (e.g., filing a complaint, answering a complaint, filing a motion, opposing a motion, serving discovery, responding to discovery, etc.) Where the motion is being eFiled, there are several more and/or different requirements. This Court continued the hearing on this matter from August 1, 2019 to September 3, 2019 for a written stipulation regarding selection of an arbitrator. By Plaintiff to Compel Defendant to Serve Initial Responses to Oppositions to motions to compel must be filed no later than 9 days before the hearing. Proc., 2025.460(b). California Rule of Court (CRC) 3.1112 (www.courts.ca.gov/cms/rules/index.cfm). H0"`A; DAlL@m@ Hr8KdH y.l(#Aa:c/ s2\eJtV9}")LupyB-j-,~8!A!A 1182, 1195 (D.D.C. RESPONDING PARTY(S): No opposition filed. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (5) To compel or to quash the production of documents or tangible things at a deposition; (6) For medical examination over objection; and, (Subd (a) amended effective January 1, 2007; previously amended effective July 1, 1987, January 1, 1992, January 1, 1997, and July 1, 2001.). A motion to compel is a motion filed against a party to a lawsuit or a third-party intended to have the court order them to do something. In addition, most of the key documents are in the District of Columbia in the Antitrust Division's pre-complaint investigation files. We have notified your account executive who will contact you shortly. Motions to compel discovery responses must comply with the deadlines of a regular noticed motion. The response must contain adequate justification for that partys objections, or argument showing why the partys answers to the discovery requests at issue were sufficient. (1) Motion to Compel Plaintiffs Deposition Testimony How do you oppose motion to compel in California? : 19STCP02316 Co. v. Atofina Chems., Inc., 2003 U.S. Dist. [W]aivers are not to be lightly inferred and the party seeking to establish a waiver bears a heavy burden of proof. (St. Agnes Med. You must consider whether you would rather have the document/video/statement/incident report, or argue that the defendant and its team of high-priced lawyers are trying to cover up the truth. He is on the Board of Governors of the Consumer Attorneys Association of Los Angeles (CAALA) and Consumer Attorneys of California (CAOC). How many pages can an opposition to a motion be in California? (Code Civ. Reply. Proc. See Pl. Plaintiff is therefore willing to withdraw its request to depose them.(7). will be able to access it on trellis. TENTATIVE RULING: However, Code of Civil Procedure section 2025.480(h) requires the moving party to lodge with the court a certified copy of any relevant portions of the transcript. This subdivision applies to the service of opposition and reply papers regarding motions for summary judgment or summary adjudication, in addition to the motions listed in may be governed by the Code of Civil Procedure (C.C.P.), the California Rules of Court (C.R.C.), local court rules, or all three. 2023.040C.C.P. 2024.020C.C.P. Proc. (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. The other party may oppose your motion by serving and filing an opposition at least nine court days prior to your hearing date. Once you have completed your motion in opposition, you should make several copies of the complete motion (and any attachments or declarations). (Complaint, 4 &am Superior Court of California If the court issues an order that compels your spouse to produce the discovery you are seeking but your spouse still refuses to provide evidence, the judge may impose further sanctions such as: Additional fees (called sanctions). (C.C.P. Defendants also kept money belonging to Plaintiff, made unauthorized charges to her credit card, and failed to provide Plaintiff with billing statements as requested. Palacios Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the The party moving to compel arbitration must establish that it demanded arbitration from the other party, and that the other party refused to agree to arbitration. [TENTATIVE] RULING RE: Even though the Court's Order granting Plaintiff, the United States of America ("Plaintiff"), the opportunity to conduct jurisdictional discovery was not limited to certain topics or time periods, Smithfield has chosen to impose its own limits and has made certain evidence about that relationship, specifically evidence up to and including the time the complaint was filed, off limits to Plaintiff in discovery, and, ultimately, to the Court in ruling on the jurisdiction question.(1). EDUARDO GUZMAN VS GUSTAVO GUTIERREZ, ET AL. Official websites use .gov ), If the court determines that a written agreement to arbitrate a controversy exists, an order to arbitrate that controversy may not be refused on the ground that the petitioner's contentions lack substantive merit. (Code of Civ. to requests for production of documents in California is made on the grounds that the requests for production of documents are objectionable in that the To strike Defendants initial responses to Plaintiffs Special Interrogatories, Set Two and to Plaintiffs Request for Production of Documents, Set Two. The requesting party files a motion to compel discovery responses if the opposing party continues to deny the discovery request. (a), emphasis added.) hb```b``b`e`6cb@ !6 " w9 &D(ap Ta/wPFOepHh +s#X4CyB/:^txp-Viq^W\vd3mYDnQ Case No. Defendant misrepresents the burden of jurisdictional discovery by combining it with the pages produced, witnesses deposed, and hours of deposition testimony from Plaintiff's substantive investigation of Smithfield's failure to comply with the Hart-Scott-Rodino Act and its "solely for the purpose of investment" defense discovery that took place before Smithfield filed its Motion to Dismiss and, indeed, before the complaint was even filed.
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