motion to compel discovery responses california22 Apr motion to compel discovery responses california

The motion must include a a good faith declaration, stating that the attempt was indeed made. 7}x[o822B,\p/f}_*MWKk+_|T_{S7 2=ei5[S[K=x;HMf u{nSS>^9T)9]V4bN5b0x{xR.LMz^MM_$AB&@0Nwf. ), Note, in Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1588, the court held that, [b]y simply hearing the motion to compel without first deciding whether discovery should be reopened for that purpose under all of the relevant circumstances, the trial court transgresse[d] the confines of the applicable principles of law and thereby abused its discretion. (citing, in part, City of Sac. <> Mishelle Neverson vs Brookdale Senior Living Communities, inc. Motion to Compel 12/04/2018 - Motion to Compel, Motion to Compel 01/19/2018 - Motion to Compel. Monetary sanctions: If sanctions are sought, C.C.P. <> 185 Those related to calculating deadlines interrelate and must be applied in the right order. <> hbbd```b``~ "[d5d/L~`b {``m0 X\ Y"?&zZ vr"d10128 _= ]7 VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord. II. OPPOSITION TO MOTION TO COMPEL FURTHER REPONSES TO REQUESTS FOR DOCUMENTS f 1 BEFORE THE HEARING. Show More. |$9hB3.ma^%]tX`s6LHi#cebB)>_CZ0CjGmV;P -Q:"H,eOx#G" ,yDF.`E%RS=i 4/30/2021 You may access and download the courts ruling from the courts website at http://www.saccourt.ca.gov. i8\x{P kGH1tC+UK_%o F&i`gPt=Ro@!er(f2HGV* ?TyS(SjbyBQ`F=] $[:,4Tf4imL/$=5(&8(Td B8/=;7e-v54"TE\E*0Il }6KSXS7YS'snR69mul0Bc/WCDM K:~v endobj This Plaintiff's Motion to Compel Further Responses to various discovery includes a (1) Notice of Motion; (2) Memorandum of Points and Authorities; (3) Meet and Confer Declaration pursuant to Code of Civil Procedure section 2016.040; (4) Separate Statement of items in dispute in compliance with California Rules of Court, rule 3.1345; and (5) Proposed Order. Parties may also move to compel further responses as to interrogatories on similar grounds. Previous questions relied on by the question at issue (for instance, if a question says, if the response to interrogatory #1 was affirmative, please state you may have to include interrogatory #1 and its response for reference). Ask Your Own Family Law Question. Caption [ATTORNEY NAME], Bar No. Meet and Confer Declaration Required. Proc., 2025.450(c)(1). App. 5 CASE NO. endobj [. 11 0 obj v. Drew (1989) 207 Cal.App.3d 1287, 1297.) (C.C.P. (Code Civ. Proc., 2025.450(c)(1). (Code Civ. This practice note discusses procedures for making and opposing motions to compel discovery in a civil action in California superior court. : For further discussion of motions to compel further responses to discovery, see California Civil Discovery Practice 15.30-15.58. But the court allowed the late motion to compel if the moving party undertook some steps. Ct. (1980) 111 Cal.App.3d 902, 905-906.) pD1visp[n5pL3lQtM;-a-VO}]ny]t;pcgj(q =vwVB~dm$ 4H^~#Ead4*KSj:sLGLvBSHr$$UKe;vtT='l6tdfIKq5'H=l#?JzT=A?qjf)$d?RTia&p%NoD]FYD/}@J!>1Za{JZ:LigFmhHgSLI a^xrJgr,6l_. Proc., 2030.290(c), 2030.300(d), 2031.310(h); see also Code Civ. Your subscription has successfully been upgraded. Proc., A Motion to Compel is governed by Federal Rule of Civil Procedure 37 and Central District of California Local Rule 37. Couns., Inc. v. Pac. [CCP 2031.310(b)(2)]. Compelling Further Response Request for Admission: [CCP 2033.290(d)]. 6 [. X {5j7"qWz+?(;ya n5kOx'nWT_y0:O|q$}c'y$[LH}?2[O.vDb6c@ !Iy|ms (Code Civ. Text of the request, interrogatory, or question. Your content views addon has successfully been added. EXTRA SPACE STORAGE, INC. when new changes related to " are available. Defendant filed oppositions on February 10, 2020. DC ki/`We]BdxeM+/nJv/ur0{" `Ww inZ e Motion ..quest is evasive or incomplete. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. endstream endobj startxref Proc., 2033.290(a).) will be able to access it on trellis. Proc., 2033 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION Motion ..quest is evasive or incomplete. Meet and confer: A prerequisite to bringing a motion to compel further responses is a reasonable and good faith attempt to informally resolve the issues presented by the motion. Hearing Date: Memorandum: Points and Authorities - Hrg 11/07/19 - in Support of Motion t, NOTICE OF MOTION AND MOTION TO COMPEL FURTHER RESPONSES TO DISCOVERY FROM , ROBIN WHITESIDE ET AL VS. ALAN BUCKLEY ET AL, SEPARATE STATEMENT SUPPORTING MOTION TO COMPEL FURTHER RESPONSES TO SET ON, NORTHERN CALIFORNIA COLLECTION SERVICE, INC. Proc., 2030.260(a), 2031.260(a). You have to digest, understand, and correctly apply them. 3 Please wait a moment while we load this page. (d)(2), 2033.210, subd. Proc., 2030.290(b), 2031.300(b), 2033.280 (a party who fails to serve a timely response to a request for admission); Leach v. Super. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. Ct. (1988) 206 Cal.App.3d 632, 636.) 10 Proc., 2033 MOTION TO COMPEL FURTHER RESPONSES TO REQUESTS FOR DOCUMENTS, FORM INTERROGATORIES, AND REQUESTS FOR ADMISSION On October 31, 2018, default was entered against Centinela. By failing to respond to an inspection demand, the offending party waives any objection to the demand. Please feel free to link to this page. TENTATIVE RULING: (Thats only the beginning of the process!). We noticed that you're using an AdBlocker, Motion to Compel Discovery Responses (CCP 2030.300). (Code of Civ. Factual support and legal argument as to why an additional response should be compelled. 4 0 obj Yj;r/triZ!fGsp0e, (12/6/18 Stipulation.) and C.R.C. <> Meet and Confer Declaration Required. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Form Interrogatories, Set O ..Centinela Gas Station, Inc. (Centinela) (collectively, Defendants). Adding your team is easy in the "Manage Company Users" tab. (3) An objection in the response is without merit or too general. Brian Leung v. Alireza Alivandivafa C.C.P. By failing to respond to an inspection demand, the offending party waives any objection to the demand. Rule 3.1348. C.C.P. mailed from California to an address in California, five calendar days are added before the sixteen court days. Defendants have not cited any authority justifying such discovery before a Rule 26(f) conference has even been held. HEARING DATE: Your subscription was successfully upgraded. m:KTsUUuipnfw=581I u`&uhPC;D}'+;9MVnH#CTxH*$i7Sr-s8tr_CKgCujAG)mR=x?L4A d7Ep;#P"Ci+Wtn U$1^g(+6o$;PjTNpP9gOaKXRu+ /6t8S8nt.XPg`q UubSQ!pwR}0AxA]co}XAg&tSd)zSi^d9~TA@YTc_n`'>2u AHtOdu[n0T-RsC6#&@7Pq8wJi;I*:Wc:[+ '&T]"$a*-.5ON} glE -ZKgKp@W{+QUa/k?-AxUPr;'NDCU9^wZ^%6q (i) Failing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning discovery, if the section governing a particular discovery motion requires the filing of a declaration stating facts showing that an attempt at informal resolution has been made. ANALYSIS: Suite 210 ( Code Civ. We have notified your account executive who will contact you shortly. .(K$f^nw2+=!AhAt! i-Cb6)gq8zX!E19PU% endobj The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories Dept: (Code Civ. [ 17 0 R] Proc., 2023.030(a), 2033.280, 2030.290, and 2031.300. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories In Sacramento, motions to compel responses to discovery are heard in either Department 53 at 1:30 p.m. or Department 54 at 9:00 a.m . y6[R}Jv+StG]{K'TR}%swsM/QN^;h{9w~*l 4M`e\ m^7q@?|UL\k:xKmt3 endobj <> Health. Background (Code Civ. ( These tasks require application of C.C.P. Dated: Date v. Drew (1989) 207 Cal.App.3d 1287, 1297.) {)-qeMFF.@WEA7}dU@@P}0PN?7wJlmR1RGMuB':ccSJF@024P;v2 LSe"UCSSu^m=Yg|lic>z ;\J pYP Summary. (This is where youve received responses to interrogatories, believe them to be incomplete, and you want the court to order the responding party to provide further responses.) To date, no reply brief has been filed. Proc., 2030.290(a), 2031.300(a). California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; Compelling Further Responses After Insufficient Responses. : Plaintiff also refiled the Motions on March 25 and 30, 2020 with accompanying declarations and separate statements. % On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. But the court allowed the late motion to compel if the moving party undertook some steps. THOMPSON VS CONTINENTAL LABOR RESOURCES, INC. Motion to Compel 01/26/2018 - Motion to Compel, Motion to Compel Further Responses to Interrogatories, Motion to Compel Responses to Request for Production of Documents, Motion to Compel Deposition of Person Most Qualified (PMQ). MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. Proc., 2030.290(c), 2030.300(d), 2031.310(h); see also Code Civ. (Theres a $15 off Coupon Code at the bottom of the page.). Theres a rule for everything in California State Court civil litigation. motion. M Would - Answered by a verified Family Lawyer . This comprises an abuse of discovery by PLAINTIFFS for which a monetary sanction is warranted under CCP 2030.290(c). Plaintiffs Motion to Compel Defendant to Provide Further Responses and Request for Sanctions is DENIED. Disclaimer: The materials and information on this website do not constitute legal advice or create an attorney-client relationship. On June 4, 2019, Plaintiff filed the following three motions: (1) Motion to Compel Further Responses For full print and download access, please subscribe at https://www.trellis.law/. #379 9l^Jg,E,sz?k=1T OZ@[{q~dG{c{l)SIG :4L~h{t-s+}:p3. If you wish to keep the information in your envelope between pages, The response and/or objections to the request. If your opposition is late, the court may ignore it. Heres a short excerpt from the Motions chapter: Lets look a bit deeper into a few of these rules. Defendants' motion to compel should be denied. : ), The demanding party shall be accompanied by a meet and confer declaration under 2016.040, or a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. ( [CCP 2025.480(b)]. 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 9 0 obj Accessing Verdicts requires a change to your plan. <>/Metadata 134 0 R/ViewerPreferences 135 0 R>> Motions to compel further responses to written discovery must be brought within 45 days (50 days if by mail) after service of the insufficient responses. Now, assuming you find all of the applicable codes and rules for this early part of the process, it is not enough to simply read them. On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (2) to produce any document, electronically stored information, or tangible thing under the deponent's control that is specified in the deposition notice or a deposition subpoena. 7 0 obj <> Proc., 2025.450(b)(2), 2030.300(b), 2031.310(b). Sanctions for failure to provide discovery. x[[o:~}bUH]"@$,M7>h ~gD]ZM$r8G}>~yzycvz6e;$\0oV,e.8Hx,c/}c Gz?Glovs1G!Bq%aC'^,Xn!D nfCLpZ(gxOQ'i1OQVna1`E/py?jEcc/YXOZ)_yZ +* 0bBzA@r#E+ky0&=psSrg {|/(/~btMq]_^S']/7t>iQ( S Sacramento, CA 95834, Privacy Policy Cookie Policy Disclaimer Attribution, Notice of Tentative Ruling Required in Notice The Notice of Motion must include the following text: Pursuant to Local Rule 3.04, the court will make a tentative ruling on the merits of this matter by 2:00 p.m., the court day before the hearing. will be able to access it on trellis. TENTATIVE RULING: >%9\%_N\>kuq%+"9$~]W-Uj^aRQ (CCP 2030.300) "E McR&Ih0T;6g,ya8aO3F%H>r!mj)ETe} f3=eK5"n2HCa+x|Fz~1PR4:o\R9tBbP8-Qy}c WxmMe1)`Msq+H;B_@9)X1#q?d,.~'ZNb3PZY2uJr`E7[ Z,y Meet and Confer Declaration Required. x\n8ow^$WA vOfw\L+")Q?wlYbbf?gWW?mw,fwso$,e Compelling Response to Interrogatories. 13 0 obj Proc., 2023.030(a). Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions try clicking the minimize button instead. Legal Standard MOTIONS Proc., 2030.260 (a), 2031.260 (a) .) Proc., 2031.310(c); 2030.300(c). We will email you Proc., 2030.260(a), 2031.260(a). by clicking the Inbox on the top right hand corner. Once [a party] fail[ed] to serve a timely response, the trial court had authority to grant [opposing party's] motion to compel responses. (Sinaiko Health. We have notified your account executive who will contact you shortly. (Code Civ. L.'P 626 0 obj <> endobj Hearing Date: Proc., 2031.310(c); 2030.300(c). California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. 8 15 0 obj Your recipients will receive an email with this envelope shortly and For further discussion of discovery in wage and hour cases from the plaintiff's perspective, see California Wage and Hour: Law and Litigation 14.30-14.36. Code Civ. u%-T\=\5j8XZjH6/A Pga$plDW;XSVLiY5$Lz3V.)g[JD?aRP#e)6(]_$^"JcJ*YiMQV +7e EM4M0 Couns., Inc. v. Pac. If you need legal advice, you should contact a lawyer. Code Civ. Copyright RPCD Holdings LLC 2003-2023 exclusive of the text of government codes. (See, e.g., Code Civ. <> Note: Identify the interrogatories in question by name and set number. 1000 21 0 obj 0 endobj (See also Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893 (trial court did not abuse its discretion in denying plaintiffs motion to compel discovery as plaintiffs separate statement did not comply with the rules of court); Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145 (trial court properly denied motions to compel discovery because of nonconforming separate statements). MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION )~?0}nF]q q3} ^+w-\_CRwh0`g}*NtOFN/>e2NtqNL1i}N^hJ"I@J$/:X\I58.WC5 -/I1_BH)"EAse,"-KhSEK xme I. << /Length 5 0 R /Filter /FlateDecode >> 3d 902, 905-906.) Proc., 2030.290(a), 2031.300(a).) This page is not legal advice, and there is no guarantee that this information is up to date. %%EOF jrIe_LHz~7Vd7Vs*V+7JrHurD8|I!WK44e#Bf*.8xUdKhOj/2>Cq5:$JV !|I|JNWc ?u_xRK+JNI^hAGF0j\V qB*Po0, Each answer to a propounded interrogatory must be as complete and straightforward as the info Jackson v. Feraj, et al. <> Otherwise the requesting party waives the right to move to compel further responses. April 30, 2021 Proc., 2033.290(a).) Rule 3.1348. (CCP 2030.300) [This, too, is covered in LBTN. On January 14, 2020, Defendant filed an Opposition. On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. ), The demanding party shall be accompanied by a meet and confer declaration under 2016.040, or a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Proc., 2025.450(b)(2), 2030.300(b), 2031.310(b). Do yourself a favor and check out this essential California civil litigation practice guide updated twice yearly. 1228 0 obj <>/Filter/FlateDecode/ID[<5D648DF4CF0B8D4198F297B63189C2D3>]/Index[1204 61]/Info 1203 0 R/Length 117/Prev 414673/Root 1205 0 R/Size 1265/Type/XRef/W[1 3 1]>>stream Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. [CCP 2030.300(b)]. 4 0 obj endobj Bus.& Prof Code 17200), First Defendant filed oppositions on February 10, 2020. (g) Disobeying a court order to provide discovery. SC129356 (Code Civ. 2 You have to know how to count to that 45th day, what to do if that day lands on a holiday or weekend, and, where the responses were not personally served, how many days by which to extend that 45-day deadline. MOTIONS 175 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. 1000 (Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1586-1587 (the fact that a party does not have a right to have a discovery motion heard after the discovery motion cutoff date does not mean the court has no power to hear it, or that the court errs in hearing it.)), A party may obtain relief from a waiver of objections to interrogatories and a request for production when the party subsequently serves responses and the failure to serve a timely response was the result of a mistake, inadvertence, or excusable neglect. ultimately in your motion, to compel further responses and further production of documents. stream Compelling Inspection or Production: [CCP 2031.300(c)]. (C.C.P. Dept: 2 0 obj endobj 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. Fortunately theres help: LBTN guides the reader through these steps. (12/6/18 Stipulation.) Proc., 2030.290(b), 2031.300(b), 2033.280 (a party who fails to serve a timely response to a request for admission); Leach v. Super. California Code of Civil Procedure section 2016.040 requires that parties meet and confer in a "reasonable and good faith attempt at an informal resolution of each issue presented by the [discovery] motion." . [CCP 2030.290(c)]. ^ci|kFC5iCPTZGhG9#cvwz&>2/DxHI4l zl}RtvNM,rru-mIi1n.~,aX2l:Kz pKbQ}"nDo,4noiI[6Qv,m, ,%}?T\8 Y Xem)f,]jmGnVYye^|lY5j2)_`gG<7fGyjW$6]k@ MB-Mm~S-O$ pUxqHCxPiJSN Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. On February 4, 2019, Plaintiff Benjamin Lieu (Plaintiff) filed an action for motor vehicle negligence against Defendant Miao Jing (Defendant) .., Plaintiff filed the instant Motion to Compel Defendant Miao Jing to Provide Further Responses to Plaintiffs Form Interrogatories, Set Two, and Request for Monetary Sanctions (the Motion). 1005(b), are just different enough from the extensions mentioned above to make it dangerously confusing (2 calendar days under one scenario; 2 court days under another). 2030.300(a).) The court must rule on the motion as if the party had appeared. ), Rules of Court, rule 3.1348(a), explains, The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after motion was filed. (See also Code Civ. when new changes related to " are available. ( <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> ), The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. You can always see your envelopes 1204 0 obj <> endobj [and/or] (2) An objection to a particular request is without merit or too general. Plaintiff also refiled the Motions on March 25 and 30, 2020 with accompanying declarations and separate statements. (See also Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893 (trial court did not abuse its discretion in denying plaintiffs motion to compel discovery as plaintiffs separate statement did not comply with the rules of court); Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145 (trial court properly denied motions to compel discovery because of nonconforming separate statements). Code Civ. endobj Last. A single procedure (e.g., filing a complaint, answering a complaint, filing a motion, opposing a motion, serving discovery, responding to discovery, etc.) Proc. Sanctions for failure to provide discovery (a) Sanctions despite no opposition The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party . 4/30/2021 On receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that any of the following apply: On receipt of a response to an inspection demand, the party demanding an inspection may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete. Your content views addon has successfully been added. CRC 2.111(4) (amended eff 1/1/17), Papers that may be filed in support of a motion include declarations, exhibits, appendices, and other documents or pleadings. 98) at 2 %PDF-1.7 3 0 obj 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. Requests for Admissions Grounds For Motion- A party may move to compel responses or additional responses to Requests for Admission if (1) a response was evasive or incomplete, or (2) an objection is made that is too general or without merit. ], Content Requirements Specific to Discovery Motions and/or Motions to Compel Further Responses. Your recipients will receive an email with this envelope shortly and Meet and Confer Declaration Required. (2) An order staying further proceedings by that party until an order for discovery is obeyed. It provides an overview of the meet and confer requirements, standards for compelling discovery, and discusses the procedural steps for making a motion to compel discovery. California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. : This Motion is made pursuant to 2030.290(b) and is based upon this Notice of Motion and Motion, the accompanying Memorandum of Points and Authorities, the (Leach v. Super. Here are just a few of the C.C.P. Parties may also move to compel further responses as to interrogatories on similar grounds. %PDF-1.5 % plain reading of California Rule of Court, Rule 3.1345(a), which provides that a separate statement is required for "[a]ny motion involving the content of a discovery request or the responses to such a request." The present motion to compel compliance does not involve the content of a discovery request or response. 2030.300(a).) Unsworn responses are tantamount to no responses at all. (Appleton v. Super. (Code Civ. subpoena. In response to the motion to compel, the Defendants charge that the discovery requests by the Plaintiff exceed the limits set by the Court. All fee documents exempt from mandatory electronic filing per LASC LR 3.4 (b) are to be filed at the filing window no later than 4:30 p.m. LASC LR 3.4 (d) (amended eff 1/1/20).

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