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New Discovery Sanction Regarding Requests for Production of Documents

By Katherine Gallo on November 8, 2020
Posted in Uncategorized

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,…

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Katherine Gallo is a renowned expert in complex discovery issues, having developed a reputation with her extensive discovery seminars, in-house discovery training and in-depth articles on the discovery process.

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  • In Order to Facilitate the Discovery Process–Serve Your Discovery in Electronic Form
  • Nail Down Whether the Documents You are Seeking ever Existed and Where They are Now 
  • New Discovery Sanction Regarding Requests for Production of Documents
  • Make Sure You are Aware of the New Document Response Requirements
  • If Plaintiff’s Bill of Particulars is Improper, Evasive and/or Incomplete; You must Bring a Motion or You Waive Your Objections

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