<]>> Responding party objects that the request seeks documents already in plaintiffs possession custody or control. Id. at 1105. Id. Id. Id. Code of Civil Procedure 2030.060(f) states, No specially prepared interrogatory shall contain subparts, or a compound, conjunctive, or disjunctive question. These types of interrogatories are easy to spot. One of the best skills that an attorney can have is weighing a question when it comes up and determining the potential impact of the answer. Id. The Court outlined the proper procedure for dealing with cases where a party seeks to obtain material that the possessor claims is subject to the attorney-client privilege. Even after acknowledging the broad nature of the requests, the Court noted that some of the requests are obviously relevant and void of ambiguity. The propounding party must ask for the time and location in separate interrogatories. See California Practice Guide: Civil Procedure Before Trial (TRG 2019) 8:322 citing Schnabel v. Superior Court(Schnabel)(1993) 5 C4th 704, 714. Id. Id. . Id. Id. 0000043163 00000 n The trial court allowed the opinion despite a prior ruling that the experts testimony be limited to his percipient observations, and despite plaintiffs repeated objections. at 1494-45. Id. 136044 sdanskin@greenhall.com MICHAEL A. ERLINGER, State Bar No. The Court of Appeals found that the trial court erred in allowing the testimony, as the testimony exceeded its limitation and touched on topics of expert opinion. The plaintiff failed to comply with discovery by refusing to testify at his first court-ordered deposition; walking out of his second deposition prior to its termination; failing to attend his third; and, refusing to provide answers to interrogatories. If any of these requests call for documents or info protected by the attorney-client privilege or the attorney work product doctrine, they are objected to. The trial court granted Defendants summary judgment motion, finding no attorney-client relationship existed. Id. at 692. . You can object to interrogatories on many grounds. at 277. App. Id. In this case, the Plaintiff testified that, although no fee had been paid, Defendant had agreed to obtain her medical records, evaluate her claim, and advise her as to the appropriate action and evidence suggested that Defendant knew the SOL would expire less than a month before he referred the case to another attorney. (citations omitted). at 1114-22.
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