UPDATED 10/23/2020
There are three motions that you can bring–(1) Motion to Compel, (2) Motion to Compel Further Responses, and (3) Motion to Have Admissions Deemed Admitted. All of them have their place in your discovery plan but two of them–Motion to Compel Further Responses and Motions to Have Matters Deemed Admitted must be in your arsenal. Though they appear to be the same motions you would use for interrogatories, inspection demands, and depositions there are a few noteworthy twists and turns.
When I was a research attorney in the Law and Motion department for Alameda County Superior Court, I handled the ex parte calendar. My judge instructed me to obtain the facts and arguments from counsel, do my own research if necessary, and present the ex parte application and my recommendation to her. Early in my career at the court, I handled an ex parte application on a case that had apparently been up and back from the Court of Appeal. When I asked for the facts of the case from counsel, he shot back at me saying “The judge knows this case because she was writted.” I told him I needed to know the facts of the case so I could provide her with my research and recommendation. He refused. When I walked back to the judge’s chambers, I overheard the counsel tell his client “She must be new because everyone knows this case.”
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In the spirit of my most recent blog,