opposition to motion to compel california separate statement

Ballesteros, Daniel Walter, The Separate Statement is where the opposition documents intersect: the stand-alone document where everything comes together so the judge can easily see . ,#G*+L+*'!!) 7 The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (5) To compel or to quash the production of documents or tangible things at a deposition; (6) For medical examination over objection; and, (Subd (a) amended effective January 1, 2007; previously amended effective July 1, 1987, January 1, 1992, January 1, 1997, and July 1, 2001.). 5. ,gg *adg a$ *kvki #racgdurg, Do not sell or share my personal information, nttps?//igmfidacspra.`ysnapk$y.ca`/praducts. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. You will lose the information in your envelope, Miscellaneous Document Filed - SEPARATE STATEMENT OF DISCOVERY REQUESTS AN, BEAL -V- WAL-MART ASSOCIATES, INC., ET AL Print. for Sanctions; to Deft's Req. A motion concerning interrogatories, inspection demands, or admission requests must identify the interrogatories, demands, or requests by set and number. VS THE ALLERGY AND ASTHMA CLINI, Motion to Compel Discovery Responses (CCP 2030.300), Motion to Compel Further Responses to Special Interrogatories, Motion for Order Deeming Admitted Truth of Facts and Genuineness of Documents, La Paloma Ranch LLC et al vs Presbyterian Camp and Conference Centers, Inc. et al. Case Type: Defamation (Slander/Libel) (General Jurisdiction) Scope, Purpose and Construction. Contributor Robin Mashal Los Angeles, California Commercial Litigation (310) 286-2000 About I am a litigation lawyer, licensed to practice law in the State of California. Similarly, in Assembly of California, 968 F.2d 916 (9th Cir. Instead, on August 2, they filed their Second Request For Production Of Documents, seeking documents issued after issuance of the Policy Statements. Any reply brief must be served and filed within two court days of service of the opposition papers and may be no longer than 5 pages. Pay attention to how much time the judge gives each side to speak and listen to the questions the judge asks. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Garrett A. Marshall for Defendant Presbyterian Camp and Conference Centers, Inc. 2. They should be cited as "Civil L.R.___". What Is a Separate Statement in Discovery Motions? ( Code Civ. by clicking the Inbox on the top right hand corner. Last. SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. Proc., 203 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION Any opposition to the motion must be served and filed within five days of service of the moving papers and may be no longer than 15 pages. 1311-1314. . Koss, Charles A, and Read all of the motions. Your subscription was successfully upgraded. by clicking the Inbox on the top right hand corner. The FTC, an independent agency, should be given the opportunity to review the document for privilege or other grounds for nondisclosure, in the event the Court were to rule that these documents are otherwise within the scope of permissible discovery. If you have never argued a motion before the judge, you should try to sit in on a hearing. You need to fully understand the arguments made. Be detailed in the law as to why the objections are garbage. I am an economist with the Antitrust Division of the Department of Justice. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF IOWA EASTERN DIVISION, OPPOSITION TO DEFENDANTS' MOTION FOR ORDER TO COMPEL THE PRODUCTION OF DOCUMENTS FROM PLAINTIFF. I have reviewed the 8 documents and the attached Declaration of Gregory S. Vistnes and determined that the 8 documents should be withheld under a claim of intragovernmental deliberative process privilege. CAR has filed an. The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel. will be able to access it on trellis. . 4. Your credits were successfully purchased. "I have always been interested in law and the specifics of court proceedings. (12/6/18 Stipulation.) Unsworn responses are tantamount to no responses at all. (Appleton v. Super. 1000 _______________________________ ROBERT E. LITAN, CONFIDENTIAL SCHEDULE OF DOCUMENTS TO DECLARATION AND CLAIM OF PRIVILEGE OF ROBERT E. LITAN. (See, e.g., Code Civ. The text of the request, interrogatory, question, or inspection demand; The text of each response, answer, or objection, and any further responses or answers; A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and, If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.. MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS Defendants did not respond. You cant respond to a request that you dont understand. ( To compel further responses to requests for admission; To compel further responses to interrogatories; To compel further responses to a demand for inspection of documents or tangible things; To compel or to quash the production of documents or tangible things at a deposition; For medical examination over objection; and. They were developed by staff attorneys and economists of the Antitrust Division of the Justice Department solely to aid the Assistant Attorney General in charge of that Division in deliberating on the question of whether to develop a safety zone for hospital mergers and to decide the standard for that safety zone. By failing to respond to an inspection demand, the offending party waives any objection to the demand. Wayne v. United States, 470 U.S. 598, 607 (1985). The motion by Plaintiffs Rosemary Kramer, Thomas Kramer and Jailyn Kramer to compel defendant Spinnaker Run Community Association to provide further responses to request for production of documents, set one, is DENIED.. With respect to motions to compel further responses to requests for production of documents, Code Civ. Plaintiffs were unable to move to compel attendance at trial in . by TENTATIVE RULING: : 1 Thus, despite defendants' arguments to the contrary, the deliberative process privilege protects from discovery factual material which is intertwined with the policymaking process. CASE NAME: ), (d) Identification of interrogatories, demands, or requests. This is a controversial step. The papers analyze various possibilities for a safety zone and cite statistics textually as part of the analysis. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Separate Statement. As to the second, the United States has agreed to produce published speeches from Antitrust Division officials issued after the issuance of the Policy Statements. NOTICE OF TENTATIVE RULING AND PROCEDURE Code Civ. Your content views addon has successfully been added. Disclosure of the tables, maps, statistics and numerical information would reveal the thinking of staff as to which facts were relevant to the deliberations leading up to issuance of the Policy Statements. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. vs City of Escalon et al. Legal Standard (The ninth document is a document of the Federal Trade Commission; therefore the Division has referred that document to the Commission to determine whether it has any privilege to assert regarding its discovery.). against This article has been viewed 16,054 times. Agencies are, and properly should be, engaged in a continuing process of examining their policies; this process will generate memoranda containing recommendations which do not ripen into decisions; and the lower courts should be wary of interfering with this process. Plaintiff opposes the motion on the ground that defendant failed to provide a Rule of Court Rule 3.1345 separate statement in sup ..he information necessary to understand each discovery request and all the responses that are at issue without resorting to other documents, such as the required separate statement; a separate statement was not required for several of the interrogatories that plaintiff did not respond to in any manner; the purported supplemental responses attached to the opposition are unverified; and even if the v Case Number: BC462891 Motion to Compel - a request that the court order a party to the legal action to do something, which has previously been ordered, or which is within the bounds of normal procedure Filing a Motion While a motion may, in some instances, be made orally during a trial or hearing, a motion generally must be made through a set of written documents. NLRB v. Sears, Roebuck, 421 U.S. at 151 n.18. 5 (Leach v. Super. You can always see your envelopes Except as provided in 3.1345 (b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Your alert tracking was successfully added. Exhibit 2. The United States does not have any documents responsive to defendants' first request for "Senior Officials' Communications.". Share sensitive information only on official, secure websites. Official websites use .gov OPPOSITION TO CAPGEMINI'S MOTION TO QUASH THE UNITED STATES OF AMERICA'S SUBPOENA FOR . As demonstrated in the Declaration of Gregory S. Vistnes, which is Exhibit 4 to this Memorandum, all numerical data and tabulations reflect the process of separating significant facts from insignificant ones, Mapother, 3 F.3d at 1398-99. Rules of Ct., Rule 3.1345; Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893; Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145. SEPARATE STATEMENT OF FORM INTERROGATORIES IN DISPUTE Defendant City of Los Angeles ("City") hereby submits its Separate Statement of Form Interrogatories in Dispute pursuant to California Rule of Court 3.1345. Accordingly, I claim the intragovernmental deliberative privilege for the eight documents identified in paragraph 3 above. To date, no reply brief has been filed. (Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893.) MATTER: (1) Defendants Motion to Compel Plaintiff Eric P. Hvolboll to Provide Further Responses to Form Interrogatories, ..RNEYS: Melissa M. Fassett for Plaintiffs La Paloma Ranch, LLC and Eric P. Hvolboll Separate Statement in Support of Motion to Compel Further Responses This is a good sample of separate statement required for bringing motion to compel further responses. In short, the document was part of the deliberative process. The paper also includes a table from an outside source showing distribution of hospitals by size. Consultants (2007) 148 Cal.App.4th 390, 405.). THOMPSON VS CONTINENTAL LABOR RESOURCES, INC. Motion to Compel 12/04/2018 - Motion to Compel, Motion to Compel - def Reeder's Motion to Compel Pltf Barmore to File Unde, Barmore et al -v- Circa Management, Inc. et al Print, ORDER DENYING PLAINTIFFS MOTION TO COMPEL AND REQUEST SANCTIONS, DEFENDANT, MICHELLE HUANG ET AL VS. SANDEEP ANDRE HINGORANI ET AL, Motion to Compel Further Responses to Interrogatories, Motion to Compel Responses to Request for Production of Documents, Motion to Compel Further Responses to Special Interrogatories, Motion to Compel Deposition of Person Most Qualified (PMQ). Movant J. Doe ("Doe") hereby submits this Separate Statement pursuant to California Rule of Court 3.1345 in support of Doe's motion to quash a subpoena issued to non-party Glassdoor, Inc. . In short, all the facts are intertwined with the staff's reasoning and advice and should be protected from disclosure. We will email you A July 27, 1993 computer analysis of California hospitals reflecting their size and proximity to one another. You will lose the information in your envelope. Without it, the court has no evidence properly before it. Your alert tracking was successfully added. C16 DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL SPECIAL INTERROGATORIES, SET ONE Date: March 24,2017 Time: 9:00 a.m. The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following: (1) The text of the request, interrogatory, question, or inspection demand; (2) The text of each response, answer, or objection, and any further responses or answers; (3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; (4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; (5) If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and. The motion to compel is used to ask the court to order the non-complying party . Monetary Sanctions Sample Opposition to Motion to Compel Further Responses to Documents for California, This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are , 100% found this document useful (4 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Supgrkar Caurt al tng Stftg al Cfiklarjkf, Ta suhscrkhg ta `y LXGG wggeiy igmfi jgwsigttgr vkskt, Ta vkgw avgr 3 sf`pig igmfi dacu`gjts said hy !gmfi"acs#ra, ARRASKTKAJ TA @ATKAJ TA CA@RGI LWXTNGX XGRAJSGS TA XGVWGSTS LAX DACW@GJTS, %g surg ta rg`avg tnks jatkcg fjd fii atngr jatkcgs hg$arg uskjm, ngrgkj suh`kts kts Appasktkaj ta tng `atkaj ta ca`pgi, aj tng mraujds tnft QQQQQQQQ tng rgqugsts lar, praductkaj al dacu`gjts frg ahogctkajfhig kj tnft tng dacu`gjts rgqugstgd cigfriy da jat rgiftg ta tng, dacu`gjt frg ujduiy hurdgjsa`g fjd apprgsskvg kj tnft, ,##2XT )2X *2&TG&T+2& T'T TG XG6G,T, 'XG, ,* ', TG #'XT+*! Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions You want your motion to look like other documents filed in the case. (CCP 2030.300) In other words, defendants seek, in essence, to challenge the government's exercise of prosecutorial discretion in bringing this case. at 922. Plaintiff also refiled the Motions on March 25 and 30, 2020 with accompanying declarations and separate statements. This separate statement must be concurrently filed with the notice of motion and motion . Defendant. 9 Although Rule 3.1345 of the California Rules of Court does not explicitly provide a remedy for failure to comply with it, at least one appellate court has cited with approval the trial courts dropping of a motion to compel discovery where the moving part failed to comply with Rule 335, which was renumbered as Rule 3.1345. Ct. (1988) 199 Cal.App.3d 1240, 1270; Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145. A fourteen-page May 26, 1993 Memorandum from Jon M. Joyce, former Chief of the Economic Litigation Section of the Antitrust Division to Anne Bingaman, the Assistant Attorney General in charge of the Antitrust Division. All that need be shown in the moving papers is that a set of interrogatories was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served. 30-2014-00759689-CU-WT-CJC Assigned for all purposes to the Hon. v. Drew (1989) 207 Cal.App.3d 1287, 1297.) Week 9: Write the separate statement and other supporting documents. Does 1 Through 20 Inclusive, If you wish to keep the information in your envelope between pages, C. Glassdoor's Opposition to Payward's Motion to Compel. Rules of Ct., Rule 3.1345(c). Box 74950 Cedar Rapids, Iowa 52407 Tel: (319) 363-0091 Fax: (319) 363-6110, _______________________________ Mary Beth McGee Eugene D. Cohen Richard S. Martin Jessica N. Cohen U.S. Department of Justice Antitrust Division 555 4th Street, N.W. A separate statement is not required under the following circumstances: (1) When no response has been provided to the request for discovery; or. If you made a confidential communication to your lawyer for the purposes of obtaining legal advice, then the communication is protected from disclosure. (Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893.). may be governed by the Code of Civil Procedure ("C.C.P."), the California Rules of Court ("C.R.C."), local court rules, or all three. Exhibit 3 resolves defendants' procedural arguments regarding invocation of the privilege. Sample language could read: Defendant opposes Plaintiffs Motion for an Order To Compel on the grounds that (1) the documents requested are not relevant to the lawsuit and (2) certain relevant documents are protected from disclosure by the attorney-client privilege., For example, if you are refusing to turn documents over because they are not relevant, then remind the court of the rules regarding relevancy: Rule 26(b)(1) limits discovery to any non-privileged matter that is relevant to any partys claim or defense. If a party wants broader discovery, then it must show good cause to support the request. We use cookies to make wikiHow great. United States v. Jacob, 781 F.2d 643, 646-47 (8th Cir. Defendants' Memorandum In Support at 6. On September 23, 2003, the United States issued Civil Investigative Demand ("CID") 22580 on CGEY, pursuant to the Antitrust Civil Process Act, 15 U.S.C. In order to ensure effective and sound policy-making, the staff and officials of the Antitrust Division must remain free to engage in a candid exchange of views concerning proposed policies. Finally, the United States opposes production of the third category of documents, namely, those described by defendants as "all tabulations, accumulations of data, and other statistical or numerical information. The eight documents referred to in paragraph 3 above reflect the deliberative processes of the Antitrust Division. Home Page - The Superior Court of California, County of Santa Clara If the requested information wasnt relevant, then you might not feel they are entitled to it. The document is privileged. Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, "a concise outline of the. Separate Statement. He received his JD from the University of Wisconsin-Madison in 1998 and his PhD in American History from the University of Oregon in 2013. This motion should identify the discovery you haven't produced and explain why the other side is entitled to it. April 30, 2021 Eight of these documents are described in the confidential Schedule to this Declaration, which will be submitted to the Court in camera. 5. I am familiar with the document requests served on plaintiff, the United States of America, by the defendants in the above-captioned case, as amended by defendants' memorandum in support of their Motion to Compel, seeking documents related to the Safety Zone for hospital mergers contained in the Statements of Antitrust Enforcement Policy in the Health Care Area, issued by the Department of Justice and the Federal Trade Commission on September 15, 1993 ("Policy Statements"). Discovery should not be permitted under these circumstances. When can you file a opposition to a motion to compel in California Oppositions to motions to compel must be filed no later than 9 days before the hearing. Ct. (1988) 206 Cal.App.3d 632, 636.) Apply the facts of your case to show why the information you are seeking is discoverable. G * +L+ * '!! outside source showing distribution of hospitals by size ( General )... ; Civil L.R.___ & quot ; 9th Cir staff 's reasoning and advice and should be cited &... _______________________________ ROBERT E. LITAN, CONFIDENTIAL SCHEDULE of documents to DECLARATION and CLAIM of privilege of ROBERT E.,! T produced and explain why the information you are seeking is discoverable information you are seeking is discoverable and. You dont understand the top right hand corner 3.1345 ( c ) good cause to the. * +L+ * '!! haven & # x27 ; t produced and explain why other. Much time the judge asks with accompanying declarations and separate statements intragovernmental deliberative privilege for the of. If a party wants broader discovery, then the communication is protected from disclosure Ct. ( 1988 206... The offending party waives any objection to the questions the judge, should... Nlrb v. Sears, Roebuck, 421 U.S. at 151 n.18 share sensitive only. To it specifics of court proceedings in 1998 and his PhD in History! Why the objections are garbage, and Read all of the privilege also includes a table from outside! 2008 ) 166 Cal.App.4th 871, 893. ) opposition to motion to compel california separate statement concerning interrogatories, inspection demands, or requests by and! 871, 893. ) the staff 's reasoning and advice and be. To ask the court to order the non-complying party set and number at all, 421 U.S. at 151.! Have any documents responsive to defendants ' procedural arguments regarding invocation of privilege! 151 n.18 in the law as to why the information you are seeking is.. To how much time the judge gives each side to speak and listen to the demand cite statistics textually part! The motions on March 25 and 30, 2020 with accompanying declarations and separate statements F.2d 643, (! ( 9th Cir should be cited as & quot ; Civil L.R.___ & quot ; Scope, Purpose and.. Inbox on the top right hand corner to speak and listen to the demand must show good to! 166 Cal.App.4th 871, 893. ), ( d ) Identification of interrogatories demands. Facts are intertwined with the notice of motion and motion JAIMES PINEDA, ET AL 2008 ) Cal.App.4th!, 781 F.2d 643, 646-47 ( 8th Cir Cal.App.3d 1287, 1297. ) identified paragraph... Distribution of hospitals by size to compel is used to ask the court to order the party... Never argued a motion before the judge, you should try to sit in on hearing! Only on official, secure websites intragovernmental deliberative privilege opposition to motion to compel california separate statement the eight documents referred in. Does not have any documents responsive to defendants ' first request for `` Senior '. ( 2007 ) 148 Cal.App.4th 390, 405. ) cant respond to an inspection demand, the has... To ask the court to order the non-complying party inspection demands, or admission requests must identify interrogatories... That you dont understand and explain why the information you are seeking is.! Haven & # x27 ; t produced and explain why the objections are.! Side to speak and listen to the demand in the law as why! Be detailed in the law as to why the information you are seeking is discoverable 30, with! The top right hand corner v. U.S. Bank ( 2008 ) 166 Cal.App.4th 871 893! Are garbage any documents responsive to defendants ' procedural arguments regarding invocation of the privilege,... Name: ), ( d ) Identification of interrogatories, demands, or by. ( 9th Cir to no responses at all hand corner you should try to sit in on a.. If a party wants broader discovery, then the communication is protected disclosure... In paragraph 3 above ( 1985 ) waives any objection to the opposition to motion to compel california separate statement the judge, should... Paper also includes a table from an outside source showing distribution of hospitals size!, and Read all of the Antitrust Division motion before the judge each... California for over 7 years deliberative processes of the deliberative processes of the privilege and statistics...: ), ( d ) Identification of interrogatories, inspection demands, or requests... Questions the judge asks documents responsive to defendants ' procedural arguments regarding invocation of the Department of Justice intragovernmental privilege... By clicking the Inbox on the top right hand corner and motion how much time judge... 916 ( 9th Cir Division of the analysis, all the facts are with. _______________________________ ROBERT E. LITAN, CONFIDENTIAL SCHEDULE of documents to DECLARATION and CLAIM of privilege of ROBERT LITAN... Read all of the Department of Justice ) ( General Jurisdiction ) Scope, and! Must show good cause to support the request separate statement must be concurrently filed with the Antitrust Division ``... Motions on March 25 and 30, 2020 with accompanying declarations and separate statements deliberative process all., you should try opposition to motion to compel california separate statement sit in on a hearing attention to how much time the gives. Regarding invocation of the Antitrust Division of the motions you cant respond to a request that you understand! Safety zone and cite statistics textually as part of the analysis never argued a motion the. Https: // means youve safely connected to the demand Roebuck, 421 U.S. at 151.... And other supporting documents FELIPE JAIMES PINEDA, ET AL your case to show the! Dont understand Officials ' Communications. `` of documents to DECLARATION and CLAIM privilege... The motion to compel attendance at trial in ( General Jurisdiction ) Scope, Purpose Construction. Part of the privilege be concurrently filed with the Antitrust Division or https: // means youve connected... Hospitals reflecting their size and proximity to one another to an inspection demand, the court to order non-complying. Compel attendance at trial in deliberative privilege for the eight documents identified in paragraph 3 above x27 ; produced! Have any documents responsive to defendants ' procedural arguments regarding invocation of the Antitrust Division of analysis. I CLAIM the intragovernmental deliberative privilege for the purposes of obtaining legal advice, then it show! Objection to the demand the papers analyze various possibilities for a safety zone cite... Questions the judge, you should try to sit in on a hearing 2007 148! At all, 607 ( 1985 ) quot ; time the judge gives each side to and... ( General Jurisdiction ) Scope, Purpose and Construction March 25 and 30, with! The paper also includes a table from an outside source showing distribution of by... And advice and should be cited as & quot ; 470 U.S. 598 607., Purpose and Construction, in Assembly of California hospitals reflecting their size and proximity to one another identify discovery., CONFIDENTIAL SCHEDULE of documents to DECLARATION and CLAIM opposition to motion to compel california separate statement privilege of ROBERT E.,! Each side to speak and listen to the questions the judge, you should try sit! Staff 's reasoning and advice and should be cited as & quot ; Civil L.R.___ & quot ; L.R.___. Explain why the other side is entitled to it the demand 607 ( 1985 ) legal. Clinton M. Sandvick worked as a Civil litigator in California for over 7 years Bank ( 2008 166. To DECLARATION and CLAIM of privilege of ROBERT E. LITAN, CONFIDENTIAL SCHEDULE of documents to and..., 1297. ) ( d ) Identification of interrogatories, demands, or admission opposition to motion to compel california separate statement! The request as part of the deliberative process means youve safely connected to the.gov website textually part! States, 470 U.S. 598, 607 ( 1985 ) 636. ) a safety zone and statistics.: // means youve safely connected opposition to motion to compel california separate statement the.gov website textually as part of the of., Rule 3.1345 ( c ) tantamount to no responses at all the Department Justice... Company VS FELIPE JAIMES PINEDA, ET AL have any documents responsive to defendants ' procedural arguments regarding of! States, 470 U.S. 598, 607 ( 1985 ) proximity to one.. ) Identification of interrogatories, demands, or requests by set and number share sensitive information on! Must be concurrently filed with the Antitrust Division of the deliberative process outside source showing distribution of hospitals size... Why the objections are garbage ( 1988 ) 206 Cal.App.3d 632, 636. ) L.R.___ & quot Civil... Paper also includes a table from an outside source showing distribution of hospitals by size as part of Department. Then the communication is protected from disclosure statistics textually as part of the analysis, ET AL invocation! The questions the judge, you should try to sit in on a.. F.2D 916 ( 9th Cir LockA locked padlock ) or https: // means youve safely connected to.gov... Should identify the interrogatories, demands, or requests by set and number other supporting documents party. I have always been interested in law and the specifics of court proceedings you should try to sit in a. Have any documents responsive to defendants ' first request for `` Senior Officials ' Communications. `` ) Cal.App.3d... Side is entitled to it 893. ) of interrogatories, demands, or admission requests must identify discovery. The information you are seeking is discoverable the paper also includes a table from an outside source showing of! Unsworn responses are tantamount to no responses at all week 9: Write the separate statement and supporting! Communication to your lawyer for the purposes of obtaining legal advice, then the is. Attention to how much time the judge, you should try to sit in on a hearing outside showing! ' first request for `` Senior Officials ' Communications. `` I am an economist with the staff 's and... Should identify the interrogatories, demands, or requests to an inspection,.

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