From the Courts’ and Legislature’s perspective, the purpose of discovery is to exchange information between the parties so each side can evaluate their strengths and weaknesses of their case, so that they are able to resolve the case or, if settlement is not possible, to safeguard against surprise at trial to avoid unnecessary delays and
The greatest discovery abuses come from responses to Requests for Production of Documents. Many responses contain a myriad of garbage objections, fail to contain a privilege log, along with producing documents that are not organized by category. Due to the responding party’s failure to comply with Codes of Civil Procedure § 2031.220, §2031.230,