Separate Statement

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Over the years, I have heard numerous motions for issue, evidence and  terminating sanctions. I found that it is difficult to rule on motions for issue and evidence sanctions if the Separate Statement is not complete. If the Separate Statement does not fully explain what you are asking for and specifically describe the numerous discovery…

Having reviewed thousands of Motions to Compel Further Responses over the years, I rely heavily on the separate statement filed with these motions.  Unfortunately, I find that many of the separate statements are deficient and not in compliance with Rule 3.1345 of the California Rules of Court.  This inevitably hurts the moving party as…