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RELATED DOCUMENTS:
California - Alameda Superior
California - Alameda Superior
California - Alameda Superior
California - Alameda Superior
California - Alameda Superior


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 Responses to Requests for Production

 Superior Court of California

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 Los Angeles

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 Timing

Service of Requests and Time for Responses

Responses to requests for production are due within 30 days (5 days in unlawful detainer actions) if the more...   

Unless, on motion of the party making the demand, the court has shortened the time for response, or more...

Service may be made by fax on written agreement of the parties. . Fax service completed after 5 p.m. is deemed to have occurred on the next court day. more...

Calculating the Deadline

The time in which any act provided by law is to be done is computed by excluding the more...

If the last day for the performance of any act provided or required by law to be performed more...

If any city, county, state, or public office, other than a branch office, is closed for the whole more...

Discovery Cut-Off--30 Days Before Initial Trial Date

Discovery must be completed on or before the 30th day before the date initially set for the trial more...

Serve Requests for Production Such That Responses Are Due Before Discovery Cut-Off

Discovery is completed on the day a response is due or on the day a deposition begins. more...

Expert Discovery Cut-Off

Expert witness discovery cut-off is 15 days, and expert witness motion cut-off is 10 days, before the initial more...

Extension By Agreement

The party demanding inspection, copying, testing, or sampling and the responding party may agree to extend the date more...

This agreement may be informal, but it shall be confirmed in a writing that specifies the extended date more...

Unless this agreement expressly states otherwise, it is effective to preserve to the responding party the right to more...

Requests for Extension

The guidelines adopted by the Los Angeles County Bar Association are adopted as civility in litigation recommendations to more...

 RESPONSE TO REQUEST FOR PRODUCTION RULES

Responses to Inspection Demands

The party to whom a demand for inspection, copying, testing, or sampling has been directed shall respond separately more...

(1) A statement that the party will comply with the particular demand for inspection, copying, testing, or sampling more...

(2) A representation that the party lacks the ability to comply with the demand for inspection, copying, testing, more...

(3) An objection to the particular demand for inspection, copying, testing, or sampling. more...

. (amended eff 6/29/09). more...

Objection the Electronically Stored Information "Not Reasonably Accessible"

If a party objects to the discovery of electronically stored information on the grounds that it is from more...

Representation of Compliance

A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed more...

Inability to Comply

A representation of inability to comply must affirm that a diligent search and a reasonable inquiry has been more...

Objection to Inspection Demand

If only part of an item in a demand is objectionable, the response must contain a statement of more...

If the responding party objects to the demand, the response shall do both of the following: more...

(1) Identify with particularity any document, tangible thing, land, or electronically stored information falling within any category of item more...

(2) Set forth clearly the extent of, and the specific ground for, the objection. If an objection is more...

. (amended eff 6/29/09). more...

Failure to Respond Timely Waives Objections

If a party to whom a demand for inspection, copying, testing, or sampling is directed fails to serve more...

(1) The party has subsequently served a response that is in substantial compliance with Sections 2031.210, 2031.220, 2031.230, 2031.240, more...

(2) The party s failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. more...

. (amended eff 6/29/09). more...

Failure to Respond May Result In Sanctions

The party making the demand may move for an order compelling response to the demand. . (amended eff 6/29/09). more...

The court must impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes more...

Sanctions and Electronically Stored Information

Absent exceptional circumstances, the court must not impose sanctions on a party or any attorney of a party more...

This subdivision shall not be construed to alter any obligation to preserve discoverable information. . (amended eff 6/29/09). more...

See Los Angeles County SmartRules procedural guide: MOTION TO COMPEL DISCOVERY. more...

Return of Privileged Electronically Stored Information ("Clawback")

If electronically stored information produced in discovery is subject to a claim of privilege or of protection as more...

Return Information of Present to Court Under Seal

After being notified of a claim of privilege or of protection, a party that received the information shall more...

No Disclosure or Use of Information Until Claim Resolved

Prior to the resolution of the motion brought under subdivision (d), a party shall be precluded from using more...

A party who received and disclosed the information before being notified of a claim of privilege or of more...

Motion to Determine Legitimacy of Claim of Privilege

If the receiving party contests the legitimacy of a claim of privilege or protection, he or she may more...

Until the legitimacy of the claim of privilege or protection is resolved, the receiving party shall preserve the more...

Preemption of Local Rules

California Rule of Court 3.20 states that the Judicial Council preempts local court rules relating to pleadings, demurrers, more...

Local Production Request Guidelines

The guidelines adopted by the Los Angeles County Bar Association are adopted as civility in litigation recommendations to more...

 Form & Format of Papers

Format of Responses to Document Demands

In the first paragraph of the response immediately below the title of the case, there shall appear the more...

Each statement of compliance, each representation, and each objection in the response shall bear the same number and more...

Response to Supplemental Requests

Responses to supplemental requests must include, immediately below the title of the case, the identity of the propounding more...

Signature on Response

The party to whom the demand for inspection, copying, testing, or sampling is directed shall sign the response more...

If that party is a public or private corporation or a partnership or association or governmental agency, one more...

The attorney for the responding party shall sign any responses that contain an objection. . (amended eff 6/29/09). more...

Additional Requirements

Los Angeles County SmartRules procedural guide: GENERALLY APPLICABLE RULES AND FORMATTING REQUIREMENTS. more...

 Filing & Service

Served But Not Filed

Within 30 days after service of a demand, the party to whom the demand is directed shall serve more...

Do Not File

The inspection demand and the response to it must not be filed with the court. . (amended 6/29/09); . more...

 Production of Documents

At Least Thirty (30) Days From Service of Demand

The date specified for production must be at least thirty (30) days (five (5) days for unlawful detainer more...

The court for good cause shown may grant leave to specify an earlier date. . more...

Specify Reasonable Place for Inspection

Specify a reasonable place for making the inspection, copying, testing, or sampling, and performing any related activity. more...

Specify Manner of Inspection

Specify any inspection, copying, testing, sampling, or related activity that is being demanded, as well as the manner more...

Organized Production

Any documents produced in response to a demand must either be produced as they are kept in the more...

The documents must be produced on the date specified in the demand, unless an objection has been made more...

If a party responding to a demand for production of electronically stored information objects to a specified form more...

Unless the parties otherwise agree or the court otherwise orders, the following shall apply: more...

(1) If a demand for production does not specify a form or forms for producing a type of more...

(2) A party need not produce the same electronically stored information in more than one form. more...

. (eff 6/29/09). more...

If necessary, the responding party at the reasonable expense of the demanding party must, through detection devices, translate more...

 

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RELATED DOCUMENTS:
California - Alameda Superior
California - Alameda Superior
California - Alameda Superior
California - Alameda Superior
California - Alameda Superior