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Demanding expert witness information in California


California designation of trade secrets under Code of Civil Procedure section 2019.0210



Enforcing a deposition subpoena in California


Notice of deposition for corporation or other fictitious entity in California


Discovery in Foreclosure Cases: Aggression can be a good thing

Excellent blog post by Neil Garfield on discovery in foreclosure defense cases and why aggression is a good thing. I agree that anyone suing the big banks over a foreclosure needs to be aggressive and be ready to file motions to compel as the banks will most likely object to almost everything. Luckily the scope of discovery in California at least is very broad and all doubts would be resolved in favor of discovery.

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see http://www.insidecounsel.com/2015/05/12/litigation-management-for-the-in-house-generalist

Discovery can be grouped into three categories: oral discovery (depositions), written discovery (interrogatories and requests for admission), and visual inspection (requests for production). These are collectively referred to as “discovery requests.” As a handy rule of thumb, you can think of discovery requests as requests to either discuss something (depositions), answer something (interrogatories), admit or deny something (requests for admission), or produce something (requests for production). You will be on both sides of discovery—you get to send discovery requests to the other party or parties, and you will receive them from the other parties. The tips and thoughts below are from the perspective of a party receiving discovery requests.

For most lawyers, discovery is simple — ask a bunch of questions or demand a visual inspection. The problems start after that. And what the banks have been counting on…

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Supplemental request for production of documents in California



Request for production of documents under Federal Rule of Civil Procedure 34



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