Ccp meet and confer discovery. Motion concerning arbitration.

4 must state, in addition to other required allegations, the provisions of the written agreement and the paragraph that provides for arbitration. Attorneys are encouraged to meet and confer early in order to explore voluntary disclosure, which includes identification of issues, identification of persons with knowledge of such issues, and exchange of documents. ” (Code Civ. 080 must be requested A Practice Note discussing motions for judgment on the pleadings in unlimited civil actions in California superior court. Evidence at Hearings Rule 5. Preparation, service, and submission of order after hearing. Read the code on FindLaw Feb 28, 2018 · When objections to discovery are raised, most jurisdictions require parties to “meet and confer” on the disputed discovery requests. 125. 050. 1330. If the parties are unable to meet and confer at least five days before the date the motion to strike must be filed, the moving party shall be granted an automatic 30-day extension of time within which to file a motion to strike, by filing and serving, on or before the date a motion to Nov 11, 2014 · Good-faith participation in discovery facilitation before filing a discovery motion with the court will satisfy the “meet and confer” requirements of CCP § 2016. 010) against any party, person, or attorney who unsuccessfully makes or opposes a motion for a protective order, 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. See Court’s website for information regarding scheduling an IDC. Read the code on FindLaw (2) The parties shall meet and confer at least five days before the date a motion to strike must be filed. §§ 2025. 040: Meet and confer declarations in civil motions essentially require the propounding party to discovery to meet and confer with opposing counsel before filing a discovery motion. 310(b)(2). " Code of Civil Procedure section 430. Before filing a motion for extraordinary discovery, a motion to compel discovery or a motion for a protective order, the parties must meet (in person or by telephone) to try to resolve or narrow the issues without court involvement. The CCP §1013 extensions for mailing apply. 113. 1345. Jan 1, 2023 · (6)(A) Either a finding that no party has established an economic inability to pay a pro rata share of the referee's fee or a finding that one or more parties has established an economic inability to pay a pro rata share of the referee's fees and that another party has agreed voluntarily to pay that additional share of the referee's fee. 7 Current as of January 01, 2023 | Updated by FindLaw Staff (a) Every pleading, petition, written notice of motion, or other similar paper shall be signed by at least one attorney of record in the attorney's individual name, or, if the party is not represented by an attorney, shall be signed Nov 14, 2019 · The purpose of the “meet and confer” requirements set forth in C. a meaningful meet-and-confer process before bringing discovery disputes to the court. What constitutes a good faith meet-and-confer effort depends on a variety of factors. Other helpful guidance documents are linked to in the checklist below. 300(b), 2031. C. This is called meet and confer. 41. ”-footnote-marker> 2-footnote-text> Because the amended rule specifically requires the parties to meet and confer in person or by 3 pages IOUT San Francisco Superior Courts Information Technology Group Document Scanning Lead Sheet Jun-01-2007 11:11 am Case Number: CPF-07-507206 Filing Date: Jun-01-2007 11:10 Juke Box: 001 Image: 01785550 ORDER IN RE: TOUFIC ANDRAOS 001001785550 Instructions: Please place this sheet on top of the document to be scanned. Facilitating Settlement; CRC 3. Pro. 290. 090. Ct. ) Monetary Dec 18, 2023 · For inspection demands, Code of Civil Procedure sections 2031. 932. All that needs to be shown 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. The purpose of meet and confer rules is to save the parties time and money and increase judicial economy by encouraging parties to resolve their disputes without Reversing the trial court's refusal to award sanctions under former Code of Civil Procedure section 2023 (now Code. 930. , §§ 2030. Declaration page limitation; exemptions; Rule 5. 727. While participating in discovery facilitation will not automatically extend the 45-day deadline to file a motion to compel further discovery response, parties may use the Jan 1, 2024 · Article 3. doc) Model Stipulated Order Re: Discovery of Electronically Stored Info (Patent Cases)(. 090 applies in most civil cases, there are exceptions. 1347(a). Documents and exhibits; Rule 3. The Code of Civil Procedure requires that parties engage in a meet-and-confer process before the filing of most discovery motions in California civil courts. The motion shall be accompanied by a meet and confer declaration under Section 2016. 182, Sec. CCP §1170. This change does not apply in: cases granted preference under Code of Civil Procedure section 36; small claims actions; probate actions; family law matters, and cases involving pro per litigants. 410 efforts on this motion overlapped with the meet and confer efforts on the companion motion to compel production of documents. pdf) Model Stipulated Orders. Sanctions are awarded in the amount of $2,460 for this motion. 320; and. ) 2 pages 1 Jeffrey D. All motions for protective orders must be accompanied by a Meet and Confer Declaration under CCP §2016. Added by Stats 2004 ch 182 (AB 3081),s 23, eff. At least 30 days before the conference, you must meet (by phone or in person) with the other side (if they have a lawyer, then with the lawyer) to discuss different parts of your case. A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. )However, “[b]efore filing a motion for judgment on the pleadings pursuant to this chapter, the moving party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to the motion for judgment on the pleadings for the purpose of determining if an Oct 26, 2021 · For a motion to compel initial responses, no meet and confer is required. 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. § 2030. e. CCP § 430. Attorneys are encouraged to propound and respond to formal discovery in a manner designed to fully implement the Jan 1, 2007 · 2024 California Rules of Court. This is also true in federal court under Rule 37(f). Jan 1, 2023 · (k) If a deponent fails to obey an order entered under this section, the failure may be considered a contempt of court. California Code of Civil Procedure CCP CA CIV PRO Section 2016. doc) (c) The party, deponent, or any other affected natural person or organization that seeks a protective order regarding the production, inspection, copying, testing, or sampling of electronically stored information on the basis that the information is from a source that is not reasonably accessible because of undue burden or expense shall bear the burden of demonstrating that the information is 2024 California Rules of Court. This Note discusses grounds for bringing a motion for judgment on the pleadings, drafting requirements such as the notice of motion and memorandum of points and authorities, service and filing issues, opposing and replying to a motion for judgment on the pleadings, possible Apr 4, 2019 · Before filing a motion to compel discovery responses, the parties must engage in a “reasonable and good faith attempt at an informal resolution of each issue presented by the motion. , Rule 3. 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. Meet and Confer. Unless otherwise limited by order of the court in accordance with this title, any party may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action or to the determination of any motion made in that action, if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of Jan 1, 2023 · California Code of Civil Procedure CCP CA CIV PRO Section 2031. ) The motion must be accompanied by a "meet and confer declaration. 931. (2) The parties shall meet and confer at least five days before the date a motion for judgment on the pleadings is filed. The plaintiff should write a letter to the defense outlining the deficiencies in their responses and requesting that they provide complete and straightforward answers. A petition to compel arbitration or to stay proceedings pursuant to Code of Civil Procedure sections 1281. Final Jul 12, 2024 · The responding party to a request for production of documents has the right to seek a protective order under CCP §2031. Rule 3. Super. Initial written discovery can be drafted and ready to serve later the same day, meaning responses may be due 30 days later. Jan 1, 2023 · California Code of Civil Procedure CCP CA CIV PRO Section 2032. II. 040 requires parties to meet and confer in a reasonable and good faith attempt to informally resolve discovery disputes before filing a motion to compel. P. A party seeking discovery may move for an order compelling an answer, designation, production, or inspection. Skinner (Bar No. Alternatively, any party can motion the court to order that the discovery period be extended so that the discovery period cutoff date is closer to the initial or postponed trial date. Code Civ. Meet-and-confer requirements; document exchange (a) Meet and confer All parties and all attorneys are required to meet and confer in person, by telephone, or as ordered by the court, before the date of the hearing relating to a Request for Order (FL-300). 4:23-5(c), after having made a good-faith attempt to meet and confer with the responding party or having notified the responding party that continued noncompliance with the discovery request will lead to a motion to Aug 23, 2021 · Meet and Confer. Discovery Motion Procedures. That includes specifically identifying in a declaration under penalty of perjury attached to a motion, the party’s efforts to obtain the requested California Code of Civil Procedure CCP CA CIV PRO Section 2030. The court may prepare the order after hearing and serve copies on the parties or their attorneys. Statement of Discovery Issues. (See LASC Local Rule 3. 050, and 2016. Insisting Attorneys Meet and Confer; Q & A; Dealing with Bickering Lawyers; CMC Order; CMC Q & A; III. 98. This motion may be made if: (i) a deponent fails to answer a question asked under Rule 30 or 31; (ii) a corporation or other entity fails to make a designation under Rule 30(b)(6) or 31(a)(4); 2024 California Rules of Court. This section requires that before filing a demurrer, “[t]he parties shall meet and confer at least five days before the date the responsive pleading is due. 280, 2023. 040. )The purpose is to enhance trial court efficiency (i. III. Jan 1, 2023 · (b)(1) A cause of action against a person arising from any act of that person in furtherance of the person's right of petition or free speech under the United States Constitution or the California Constitution in connection with a public issue shall be subject to a special motion to strike, unless the court determines that the plaintiff has established that there is a probability that the When a responding party declines to turn over requested documents, the requesting party may file a motion to compel discovery , R. 010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to extend or to reopen discovery, 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. ” Also, make sure to check your local rules and This checklist should help guide you through the process of preparing before the FRCP 26(f) meet and confer. Read the code on FindLaw Unless otherwise authorized by the court, discovery meet and confer obligations require an in-person, telephonic, or video conference between parties. 040(b)(1). 290 if the responding party: Fails to respond; The trial courts have discretion to consolidate actions involving common questions of law or fact and are pending in the same court. 300(b); Cal. , to avoid unnecessary duplication of evidence and procedures); and to avoid the substantial danger of inconsistent adjudications (i. Nov 16, 2020 · California Code of Civil Procedure section 2016. Do not exceed 2 pages. Proc. Prior to the Final Status Conference, counsel are ordered to meet and confer via a safe remote procedure to exchange, discuss, and prepare for submission to the court, all necessary documents indicated below. Feb 22, 2021 · Meet and Confer “A party may move for judgment on the pleadings. 112. 1. Some courts have held that the meet and confer rule requires personal consultation, either in person or by telephone, or that the parties attempt to directly confer with one another. If the parties are unable to meet and confer by that time, the moving party shall be granted an automatic 30-day extension of time within which to file a motion for judgment on the pleadings, by filing and serving, on or before the date a motion for judgment on the Apr 10, 2024 · While Section 2016. Motions to compel further responses to document requests, inter-rogatories, and requests for Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031. This "meet and confer" process is mandatory. , § 2025. Read the code on FindLaw A motion to compel further responses to interrogatories must include a meet and confer declaration pursuant to the Code of Civil Procedure § 2016. The “meet and confer” requirement is your opportunity to demonstrate to the court that you are making a “reasonable and good faith attempt at an informal resolution. At least 15 days before the conference, you must file and serve a Case Management Statement. 700, no party may move to compel discovery or file any other discovery motion until the parties have had an Informal Discovery Conference (IDC) with the Court. Jun 17, 2024 · Meet and Confer: Before filing the motion, the plaintiff must make a reasonable and good faith attempt to informally resolve the discovery dispute with the defendant (CCP § 2016. ” California Code of Civil Procedure (CCP) § 2016. § 2031. Format of Discovery Rule 3. Leach v. For requests for admission, Code of Civil Procedure sections 2033. If a resolution is not reached, an Informal Discovery Conference (“IDC”) with the court pursuant to Code of Civil Procedure Section 2016. Jan 29, 2024 · to meet and confer by videoconference, telephone or in person no later than 20 calendar days before the date set for the initial and any succeeding Case Management Conference to consider each of the issues identified in CRC, rules 3. ” What does that really mean? (d) Meet and confer requirement The court may order counsel to meet privately before the initial case management conference to discuss the items specified in (a) and to prepare a joint statement of matters agreed upon, matters on which the court must rule at the conference, and a description of the major legal and factual issues involved in the Meet and Confer Requirement Within the Commonwealth, Pennsylvania Courts may require compliance with local rules such as the following for Montgomery County Rule of Civil Procedure 208. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; Why is this “Golden Rule” letter necessary when the answers are obviously deficient? Most jurisdictions require a meet-and-confer letter for deficient discovery request responses before you can file a motion to compel. This is called "meet and confer. Motion concerning arbitration. 010) and the prior version of Code of Civil Procedure section 128. Discovery . (Code of Civ. " (Code Civ. MICHAEL J. 724 and 3. 724. Discovery Chapter 1. A motion to compel further responses to interrogatories must include a meet and confer declaration pursuant to Code of Civil Procedure, § 2016. 290 was for the lawyers to revisit their position, and in good faith, discuss a resolution in order to avoid unnecessary discovery motions. The local rule states, in relevant part: Jan 1, 2023 · (c) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023. Rules Applicable to References Under Code of Civil Procedure Section 638 or 639 Rule 3. (a) Before filing a demurrer pursuant to this chapter, the demurring party shall meet and confer in person, by telephone, or by video conference with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be raised in the demurrer. Unless the court orders another time period, no later than 30 calendar days before the date set for the initial case management conference, the parties must meet and confer, in person or by telephone, to consider a number of ESI-related issues, including: Issues relating to the preservation of discoverable ESI; Jan 1, 2007 · (3) Any party or attorney of record may be physically present at the deposition at the location of the deponent with written notice of such appearance served by personal delivery, email, or fax, at least five court days before the deposition, and subject to Code of Civil Procedure section 2025. Section 2016. Live testimony; Rule 5. § 2024. CCP §2024. 25. 122155) 5 SERLIN & WHITEFORD LLP 701 E Street 6 Sacramento, CA 95814 Telephone: (916)446-0790 7 Facsimile: (916)446-0791 Attomeys for Plaintiffs-in-Intervention THE CALIFORNIA STATE GRANGE and ED KOMSKI 430. Interrogatories. Civ. 111. Jan 1, 2023 · (c) Employing a discovery method in a manner or to an extent that causes unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. ) Jan 1, 2023 · California Code of Civil Procedure CCP CA CIV PRO Section 2033. 1348. Model Stipulated Order Re: Discovery of Electronically Stored Info (Standard Cases)(. This meet and confer starts the discovery clock. Jun 1, 2010 · In enacting this rule change, California’s Judicial Council specifically intended to “ensure that parties and the courts address issues relating to electronic discovery early in the course of litigation. 090 is also accompanied by changes to Section 2023. There are separate checklists that can help during and after the FRCP 26(f) meet and confer as well. This is a mandatory requirement (see CCP §2016. 080 FOR COURT US TELEPHONE NO. 2016. 310. 450(b)(2), 2025. 8) Meet and Confer is not technically required if no responses have been received, but in practice Court is more likely to grant sanctions if you made an attempt to meet and confer prior to filing. Jul 12, 2024 · Declaration supporting the Motion to Compel and a Meet and Confer statement - state facts supporting your motion to compel and showing you made a good faith and reasonable effort to resolve your discovery issue with the opposing party. Declarations supporting and responding to a request for court order; Rule 5. Duty to meet and confer. Seriin (Bar No. See Overview – Initial Disclosures under Rule 26(a); Overview – Discovery Plan; Form – Discovery Plan. A discovery motion may be made at any time on giving five days' notice. (Added by Stats. This is comprised of an hourly rate of $400 multiplied by 6 hours (4 for drafting the motion and 2 for meet and confer efforts), plus the $60 filing fee. When dealing with an adversary that is difficult to reason with or trust over the phone, it is best to prepare a letter that specifically outlines which discovery responses you believe are deficient and do not Jan 1, 2023 · California Code of Civil Procedure CCP CA CIV PRO Section 2033. ) “The motion shall be accompanied by a meet and confer declaration under § 2016. 300 is a legal action taken when a party fails to serve timely responses to discovery requests, such as interrogatories or requests for production. New Rules. First, when responding to requests for production, the produced documents must identify the specific request to which they respond. 115. (Code Civ. So it cannot happen immediately, but neither does one have forever Insisting Attorneys Meet and Confer; Q & A; Dealing with Bickering Lawyers; CMC Order; CMC Q & A; III. Meet and Confer declaration and separate statement required to compel further answers (CRC 3. A. 2024 California Rules of Court. 040 Summary A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. A meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. Judicial notice; Article 5. 220. 1345) Timing Considerations (c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or any specific later date to which the requesting party and the responding party have agreed in writing, the requesting party waives any right to compel further response to the requests for admission. All discovery must be completed 5 days before trial. : ATTORNEY FOR (NAME): Briefly describe the nature of the discovery dispute, including the facts and legal arguments at issue. 2004, Ch. A Meet and Confer Declaration is Required. ESI PERSON(S) MOST KNOWLEDGEABLE The parties have identified ESI Person(s) Most Knowledgeable (“ESI PMK”) to each other who are and will be knowledgeable about and responsible for discussing their respective ESI. Jun 3, 2022 · We are willing to stipulate to the appointment of a Discovery Referee pursuant to Code of Civil Procedure section 639, subdivision (a)(5), for the limited purpose of aiding us in a meet and confer session, hearing any motion to compel further responses if filed and/or preparing a recommendation to the court. 310(b), 2032. Read the code on FindLaw The motion shall be accompanied by a meet and confer If the party California Code of Civil Procedure section 2016. , § 438(b)(1). 420. Open proceedings, notice of proceedings, and order for hearing site; Rule 3. 040, per Local Rule 3. 8. Code § 2016. ADR . 5. FindLaw. MANDEL, ESQ. The rule previously Dec 12, 2020 · The moving party must state “specific facts showing good cause justifying the discovery sought by the inspection demand. 030. 300–2031. URCP 37. 010) against any party, person, or attorney who unsuccessfully makes or opposes a motion for a protective order under this section, 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. 41 and 435. Final Dec 1, 2015 · Guidelines for the Discovery of Electronically Stored Information (. 239214) SCHIFF HARDIN LLP 2 901 K Street NW, Suite 700 Washington, DC 20001 3 Telephone: (202) 778-6400 Facsimile: (202)778-6460 4 Mark A. Any opposition to a discovery motion and any reply to an opposition may be made orally at the time of hearing. , § 1048(a). Rules of Ct. An extension of time to file a responsive pleading may also be granted under Code of Civil Procedure, § 430. Rule 5. 310(b)(2); Cal. (b) The court, for good cause shown, may make any order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. Unless the court orders another time period, no later than 30 calendar days before the date set for the initial case management conference, the parties must meet and confer, in person or by telephone, to consider each of the issues identified in rule 3. 727 and, in addition, to consider the following: Meet and Confer, and Special Statement. (B) To Compel a Discovery Response. 41 requires that “[b]efore filing a demurrer pursuant to this chapter, the demurring party shall meet and confer in person or by telephone with the party who filed the pleading that is subject to demurrer for the purpose of determining whether an agreement can be reached that would resolve the objections to be This motion shall be accompanied by a meet and confer declaration under Section 2016. , § 2023. 2(e). In addition, if the disobedient deponent is a party to the action or an officer, director, managing agent, or employee of a party, the court may make those orders that are just against the disobedient party, or against the party with whom the disobedient deponent is In general, before a demurrer or a motion to strike can be filed, the law requires that the two sides try to solve the issue either in person or by phone. Rule 26 conference and when seeking to resolve discovery disputes about ESI during meet-and-confer conferences. ” CCP §2016. 5, the court of appeal ordered a new trial and sanctions at least sufficient to compensate the plaintiff for the attorney fees and costs of the I. Meet-and-confer requirements; document exchange; Article 4. Cal Rules of Ct 3. 050(a). 1000. The propounding party may move to compel responses to interrogatories under Code of Civil Procedure section 2030. 280–2033. Ca. 7/1/2005. ) Counsel shall also attempt to reach stipulations with regard to ultimate facts and . Jun 10, 2022 · We are willing to stipulate to the appointment of a Discovery Referee pursuant to Code of Civil Procedure section 639, subdivision (a)(5), for the limited purpose of aiding us in a meet and confer session, hearing any motion to compel further responses if filed and/or preparing a recommendation to the court. A sample “meet and confer” letter is included at the end of this Guide. , different results because tried before Before you start Try to work things out informally with the other person If you sent a request for information using the discovery process and the other person: Skipped some questions that you checked Did not answer the whole question Refused to answer without a good reason Did not respond at all to your discovery request you have options for what to do next to get the information you need. 040). Oct 29, 2019 · ESI Meet-and-Confer Requirement. Read the code on FindLaw A meet and confer declaration in support of a motion shall state (c) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023. 040 and a separate statement. " Jan 1, 2023 · (b)(1) The motion shall be supported by affidavits, declarations, admissions, answers to interrogatories, depositions, and matters of which judicial notice shall or may be taken. Jan 1, 2023 · California Code, Code of Civil Procedure - CCP § 128. After reviewing the 2023 discovery statutes, there have been changes to the following statutes: The most significant change in the 2023 discovery statutes is the repealing of C. Nov 15, 2020 · A Motion to Compel Discovery Responses in California under CCP § 2030. Meet-and-Confer Conferences Rule 5. 310(b)(1). Nov 29, 2022 · CCP Section 2016. 060. 040 - Meet and confer declaration in support of motion. pdf) ESI checklist for use during the Rule 26(f) meet and confer process (. ” (Code of Civ. Introduction; Informal Discovery; Discussing the Informal Discovery Conference a the CMC; Informal Discovery Conferences; Q & A; IV. You must provide the court with a declaration, including facts Jun 17, 2024 · Meet and Confer: CCP § 2016. ) CCP§ 2016. Motions or applications to be heard by the court; Division 10. 450(b)(2). (1980) 111 Cal. Format of discovery motions (a) Separate statement required Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. See discovery blog titled “If Meet and Confer fails, Ask for Help. (CCP §1170. 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 By means of demands for production of documents, written questions submitted (interrogatories and Requests for Admissions) and depositions (oral examination under oath before a reporter) the typical litigator in the United States will spend a hundred hours conducting discovery for every hour spent in the court room. 2 and 1281. 23. Jan 1, 2023 · (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023. 480, 2030. 080 Informal Discovery Conference. Example Meet and Confer Letter Addressing Discovery Deficiencies Chapter 3. If an amended com Nov 3, 2010 · In the best case scenario, a litigant will send a meet and confer letter about discovery responses the day after receiving them, and will set a date for supplemental or amended responses, and then move to compel if supplemental/amended responses are not received by theat date. MEET AND CONFER 1. Attach a supporting “Meet and Confer” declaration (CCP §2016. What meet and confer declaration in support of motion must show, Cal Code Civ Proc § 2016. In addition to the meet and confer requirements of CCP §2016. App 3d 902, 905-06. 221; Discussing Type and Timing of ADR; Q & A; V. com - California Code, Code of Civil Procedure - CCP § 2025. 250 and 2033. im zo sa jy sb on vd ff ug vv