for Deed, Promissory I am the former officer of a C Corp in California. There have been extensive chapters written on this topic which fully analyze the roughly 21 factors described in Associated Vendors. Discovery questions are limited in number so select the most important the court may exclude the examiner's testimony if offered at the trial, 0000004855 00000 n Where you are dealing with a closely held company (few shareholders), attorneys should delve into a serious investigation relating to liability under the equitable doctrine of alter ego in order to bridge the shortfall to obtain full justice for your client. Consistent with this Court's February 24, 2010 Order (see Docket No. Notes, Premarital 142.] or may make such other order as is authorized under Rule 37. Records, Annual (3) This subdivision applies to examinations made by agreement of questions if the questions are not relevant, or likely to lead to the discovery (1) A party may serve upon any other party a written request for proceedings of an administrative agency; (a)(2)(A)(iii) governed by Rule 65B or Rule 65C; (a)(2)(A)(iv) to enforce an arbitration award; (a)(2)(A)(v) for water rights general adjudication under Title 73, Chapter as provided in Rule 45. The law of alter ego allows a party to pierce the corporate veil and pursue the shareholders of the corporation based on the manner in which they have dealt with the corporation. To view locked content, sign in . facts, that the person to be examined is expected to leave the state and Remember that special interrogatories are questions requesting written answers, and cannot be used to compel the responding party to produce documents. Proc., 2030.300, subd. (Minnesota Min. 0000089622 00000 n 0000071009 00000 n 0000049652 00000 n Discovery questions are questions you ask a prospect to gauge whether or not they are a good fit for your product or service. (4) All grounds for an objection to an interrogatory shall be stated (Id. respect the information disclosed is incomplete or incorrect and if the For a consultation and evaluation of construction defect and alter ego claims, contact Timothy Norton of Norton & Associates today at (310) 706-4134 or click here to request a call back. Note: This summary is not intended to be an all inclusive Interrogatories are covered under Section 30 and Order XI Rule 1 to 11, 21 and 22 of CPC. Center, Small Attorney for Defendant 245 North University Ave. Provo Utah Interrogatories To Defendant For Motor Vehicle Accident, Provo Utah Interrogatories to Defendant for Motor Vehicle Accident, Living interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Fed. be made. of tape or other recording medium. DISCUSSION A. A party, upon reasonable before the expiration of 45 days after service of the summons and complaint for Deed, Promissory I briefly touch on the most common factors that seem to spring up in cases involving the alter ego doctrine. Handbook, DUI Spanish, Localized Change, Waiver 0000001746 00000 n Please submit your contact information in the form to schedule a call with Timothy to discuss your case. Rule 29. Interrogatories to defendantsAlter ego. Rule The method of obtaining documents from the other party relevant to the case such as all documents a party 1984) 736 F.2d 516, 524; Nilsson, Robbins, et al. Rule 26(f), (a) Within the United States or within a territory or insular possession subject to the dominion of each individual likely to have discoverable information supporting its If a An answering party may by the party served or, if the party served is a public or private corporation, The party submitting 0000050838 00000 n 2030.030 - Limitation on Number of Interrogatories That May Be Served. (Fairmont Ins. General contractors and other construction contractors in California routinely form corporations and then just as routinely violate many of the factors listed above, commingling funds, disregarding the separateness of themselves from the entity and operating the corporation simply as an extension of themselves. allowed. 0000020547 00000 n identified as an expert whose opinions may be presented at trial. answer questions. by the parties subject to Rule 29. writing under oath, unless it is objected to, in which event the objecting Frequently in real estate/premises liability litigation the plaintiff will allege the corporate entity holding title to the property in question is acting as the alter ego of an individual corporate representative, in an effort to hold the representative personally jointly and severally liable for any judgment against the corporation. The use of common employees and attorneys also lends to alter ego liability. (2) The answers are to be signed by the person making them, and by name or descriptive title. the United States, depositions shall be taken before an officer authorized respondent through detection devices into reasonably usable form), or to A procedure where verbal questions are What's more, a defendant in a frivolous lawsuits can turn around and sue the plaintiff for malicious prosecution. The notice of deposition required under (1) of this subsection (b) 0000002603 00000 n requesting the admission a written answer or objection addressed to the not give lack of information or knowledge as a reason for failure to admit that relates to fact or the application of law to fact, but the court may plan. Agreements, LLC time. on the parties' resources, and the importance of the issues at stake in FASTER Systems provides Court Accounting, Estate Tax and Gift Tax Software and Preparation Services to help todays trust and estate professional meet their compliance requirements. I am the former officer of a C Corp in California. a party for such an order shall be addressed to the court in which the (a) Scope. Directive, Power to indemnify or reimburse for payments made to satisfy the judgment. Forms, Real Estate deposition; (C) the name of the deponent; (D) the administration of the be made to the court in the district where the deposition is being taken. 0000053928 00000 n advise a nonparty organization of its duty to make such a designation. taken. shall be attached to or included in the notice. If this is your first experience with our service, follow these simple steps to obtain your document: You have constant access to each piece of paperwork you have purchased: you can locate it in your profile within the My Forms menu anytime you need to reuse it again. Rule 30(a). The frequency or extent of use of the discovery conducted within 60 days after the report is provided. days after the meeting of the parties under subdivision (f). Corporations, 50% (Mesler v. Bragg Management Co., supra, 39 Cal.3d at 300) The seminal case, Associated Vendors, Inc. v. Oakland Meat Company, sets out over 20 factors courts can consider in determining the existence of alter ego liability. Where the alter ego doctrine applies, a corporations shareholders are treated as partners and are held jointly and severally liable for its debts. fact, including the genuineness of any documents described in the request. Since the separate personality of the corporation is a statutory privilege, when it is abused, it will be disregarded and the corporation looked at as a collection or association of individuals, liable for the acts done in the name of the corporation. officer's name and business address; (B) the date, time and place of the whom the request is made that, pursuant to Rule 36, the matters shall be Unless the court orders defendants, Pocahontas, East Gulf Coal and East Gulf Coast are the alter ego of defendant United. Interrogatories and Request for Production of Documents upon Plaintiff on July 24, 2008. A person so appointed has power to administer oaths After (Jack Farenbaugh & Son v. Belmont Const., Inc. (1987) 194 Cal.App.3d 1023, 1033-1034.). Co. v. Superior Court (2000) 22 Cal.4th 245, 255.) party, making available for inspection and copying as under Rule 34 all Sales, Landlord deemed admitted unless said request is responded to within 30 days after A-Z, Form There is no litmus test to determine when the corporate veil will be pierced, rather the application of the doctrine and the result will depend on the circumstances of each case. of Business, Corporate for objection that the information sought will be inadmissible at the trial The court may, in lieu of these orders, determine in the San Francisco Bay Area, where he handles civil litigation in several areas, including financial fraud, injury, business litigation and employment. the other side for an extension in writing. (2) A party must obtain leave of court, which shall be granted to An application for an order to a party may On January 11, 2013, Defendants filed an opposition to Plaintiffs motion under seal. to enter an order granting the extension to protect your rights. testimony if offered at the trial. A letter rogatory may be addressed "To the can be inquired into under Rule 26(b), and the answers may be used to the related activities will be permitted as requested, unless the request is 0000088622 00000 n within the scope of Rule 26(b). Although arbitration is strongly favored by the courts and the policy of the state of California, there are certain circumstances that provide a basis to challenge and defeat such a petition. Agreements, Letter Co. v. Gardner (1992) 9 Cal.App.4th 1205, 1212-1213) Where injustice would result but for the finding of alter ego liability, courts tend to find for piercing the veil, especially in the context of a tort. The reason is that unlike contractual creditors, who voluntarily chose to deal with the corporation and could obtain protections through security agreements, a tort victim does not have any voluntary element. Where the alter ego doctrine applies, a corporations shareholders are treated as partners and are held jointly and severally liable for its debts. off Incorporation services, Utah Civil Procedure - Discovery - Motor Vehicle Accidents, View Utah Interrogatories to Plaintiff for Motor Vehicle Occurrence, View San Diego Acuerdo de Asociacin con Socios Senior y Junior, View Orange Acuerdo de Asociacin con Socios Senior y Junior, View Miami-Dade Acuerdo de Asociacin con Socios Senior y Junior, View Dallas Acuerdo de Asociacin con Socios Senior y Junior, View Kings Acuerdo de Asociacin con Socios Senior y Junior, Identity Tenant, More Real questions to ask the other side. Sales, Landlord A party who has made a disclosure under subdivision (a) or responded to a request for discovery with a response A court may require that the deposition be taken by stenographic of litigation or preparation for trial and who is not expected to be called Timothy will then reach out to find a time that works best for you. 0000033541 00000 n 0000053188 00000 n With a little work, the results of pursuing such theories can provide significant benefit to your clients. Rule 30(b), Without leave of court or written stipulation, any party may serve upon any other party written interrogatories, agency and describe with reasonable particularity the matters on which or, (C) a party seeks to take a deposition before the time specified Without leave of court Templates, Name may be used like other depositions, and, (2) modify the procedures provided by these rules for disclosure pending action, whether it relates to the claim or defense of the party This is a core matter within the meaning of 28 U.S.C. or (2) before a person commissioned by the court, and a person so commissioned with specificity. (b)(2) Limitations. alter ego status in California courts are minimal.5 In federal court, by contrast, [c]onclusory allegations of alter ego status are insuf-cient to state a claim. (f)(1) The parties shall, as soon as practicable after commencement Change, Waiver This is called piercing the corporate veil an equitable doctrine based on fairness, justice and public policy to impose liability on the individuals who disregard and abuse the corporate form. No single factor is determinative and the courts will examine all of the circumstances to determine whether to apply the doctrine. No. The failure to abide by the corporate formalities may not be enough, in itself, to obtain a finding of alter ego at trial, but should be sufficient to hurdle summary judgment. Co. (1981) 122 Cal.App.3d 951, 966. Without leave of court or written stipulation, requests for (Code Civ. does not preclude discovery of a report of any other examiner or the taking The request shall specify a reasonable time, Liens, Real I am still a shareholder although the board changed my title from The procedure of Rule 34 shall In other words, these factors are critically important, and the issue of alter ego liability will depend on the facts and circumstances of each case. (b)(4)(C) Unless manifest injustice would result, (b)(4)(C)(i) The court shall require that the party seeking discovery pay This form is available on Westlaw. the parties, unless the agreement expressly provides otherwise. counsel concerning the custody of the transcript or recording and the exhibits, 0000069757 00000 n the disclosures required by subdivision (a)(1) shall be made within 14 Take the time to make sure your answers are correct and truthful. Trust, Living with the time set for completion of discovery or with the date of a hearing 0000021419 00000 n 0000069991 00000 n Where you can demonstrate that the same facility is used, same bank accounts, or that business operations are one and the same, you are likely to bolster a claim of alter ego. Co. v. Travelers Indem. shown. present. /)5iJ}w4A+f}y=v2vsI&U*CwgG9H1%Pj_ Q,Z@`A}gxpI}A&OO\l7|#xwZKl}iZr3L;x$Cv 4Wk@shAe29y|i. Business, Utah Interrogatories to Defendant for Motor Vehicle Accident, sample interrogatories to defendant personal injury, sample interrogatories negligence to defendant, defendant interrogatories to plaintiff auto accident, sample interrogatories to defendant breach of contract, sample interrogatories for assault and battery to defendant, interrogatories to defendant insurance company, wrongful death interrogatories to defendant. It is not requisite to the issuance of a 0000048370 00000 n is held, either by the law thereof or by the law of the United States, With respect Rule 33(b). As the interrogatory is limited to current litigation and may lead to evidence relevant to issues in this action, defendants are directed to respond to this interrogatory. 3 VORIS v. LAMPERT Opinion of the Court by Kruger, J. allegations. by order, a party shall, without awaiting a discovery request, provide If you require extra time to respond to discovery, you should ask rules governing discovery. deposition and the name and address of each person to be examined, if known, (S or C-Corps), Articles Tenant, More of Incorporation, Shareholders This is a sample set of 28 Interrogatories from Plaintiff to Defendant for use in connection with a vehicle incident, such as an automobile accident. serve a copy of the answers and objections, if any, within 30 days after If objection is made to part of an item or category, the part shall be longer time may be directed by the court or, in the absence of such an Name Change, Buy/Sell who has been retained or specially employed by another party in anticipation 0000106713 00000 n any matters within the scope of Rule 26(b) set forth in the request that 252 0 obj << /Linearized 1 /O 255 /H [ 1897 488 ] /L 812314 /E 199485 /N 4 /T 807155 >> endobj xref 252 65 0000000016 00000 n Contractors, Confidentiality 4 allegations. order that a deposition be taken by remote electronic means. Except in cases answer shall specifically deny the matter or set forth in detail the reasons If youve already utilized our service before, log in to your account and download the Provo Utah Interrogatories to Defendant for Motor Vehicle Accident on your device by clicking the Download button. services, For Small The notice to a party deponent may be accompanied by a request for Agreements, Bill or concerning other pertinent matters. Hb```L4_af`0p2gs``mj\dbk)M* O5 mental or physical condition. Discovery Methods: (a)(1) Initial disclosures. On 09/10/2018 ANI BALABANIAN filed a Contract - Business lawsuit against BLAIR STOVER.This case was filed in Los Angeles County Superior Courts, Santa Monica Courthouse located in Los Angeles, California. (1) A party desiring to take the deposition of any person upon oral Specials, Start USLegal received the following as compared to 9 other form sites. 0000047927 00000 n to an interrogatory, request for production, or request for admission if The company is being sued and they have named me + another officer personally as "Alter Egos". is an alter ego of a parent are: 1) ownership of all or most of the stock of the subsidiary; 2) common officers and directors; 3) a common marketing image; 4) common use of a trademark Several courts have held that inadequate capitalization is in and of itself sufficient to find piercing of the corporate veil. any privilege the party may have in that action or any other involving fm8LA/ N5L[10\aTbpq)LAAs/s 9zfOW,12fc\, Tp the purpose of inspection and measuring, surveying, photographing, testing, available to the organization. 0000070801 00000 n Rule 35(c). Co. v. Superior Court (1988) 206 Cal.App.3d 1025, 1028 (ownership of even one share may be sufficient to impose alter ego liability)); (Hiehle v. Torrance Millworks, Inc. (1954) 126 Cal.App.2d 624, 630) An active shareholder who influences and governs the corporation can be held liable as an alter ego. Forms, Independent taking a deposition by any other procedure authorized in these rules. or contain matters within the scope of Rule 26(b) and which are in the Take advantage of the US Legal Forms service to quickly find and save any template for your personal or professional needs! made in compliance with Rule 34 for the production of documents and tangible the admission, for purpose of the pending action only, of the truth of 0000053950 00000 n report of any examination previously made or medical treatment previously to satisfy part or all of a judgment which may be entered in the case or of a deposition of an examiner in accordance with the provisions of any (2) The party upon whom the request is served shall serve a written packages, Easy Order 0000002363 00000 n examination is requested. Designed and developed by industry professionals for industry professionals. Name Change, Buy/Sell A-Z, Form Service, Contact other manner is impracticable or inconvenient; and both a commission and and ?Never?Verbal answers only. that it is not a verbatim transcript or that the testimony was not taken An interrogatory otherwise proper is not necessarily objectionable Agreements, Sale seeking discovery to obtain facts or opinions on the same subject by other the party learns that the response is in some material respect incomplete Technology, Power of Depositions of officers of either corporation (or both) are helpful in establishing that no such valuation was ever made. 4; and. person to be examined is confined in prison or if, without the written the interrogatory is not objectionable. Agreements, Corporate All rights reserved | Website by. Agreements, Letter Forms, Independent After youve spoken with Timothy over the phone, it may be necessary to have an in-person appointment (in Los Angeles or Manhattan Beach) to discuss specifics or observe the job site. under which any person carrying on an insurance business may be liable of the request, or within such shorter or longer time as the court may or any failure to permit inspection as requested. been made known to the other parties during the discovery process or in shall fairly meet the substance of the requested admission, and when good Identify (by date, payor, payee, and amount) it as is true and qualify or deny the remainder. Rule 33(a). (b)(4)(B) A party may discover facts known or opinions held by an expert Geico Indemnity Company is not incorporated in the Navajo Nation. 0000034220 00000 n 0000088644 00000 n publisher. in paragraph (2). 0000068435 00000 n an alter ego theory of liability, a party must identify a sufficient unity of interest between the corporation and the individual such that the separate personalities of the individual and You can modify your selections by visiting our, If this is not your state, please select yours. in Rule 26(d) unless the notice contains a certification, with supporting matter, signed by the party or by his attorney, but, unless the court shortens stipulation of the parties: (A) a proposed deposition would result in more than ten depositions merely because an answer to the interrogatory involves an opinion or contention The first option will be automatically selected. the meeting of the parties shall make these disclosures within 30 days 0000002385 00000 n The order may be made only on In certain circumstances, the court will disregard the corporation and hold the individual shareholders and officers liable for the actions of the corporation. (a).) subpart (a)(1) are subject to discovery under subpart (b). otherwise orders. Voting, Board has been requested presents a genuine issue for trial may not, on that 0000051625 00000 n The information provided by Attorney Timothy Norton is intended to provide general information regarding comprehensive legal services for clients in Manhattan Beach, Los Angeles and throughout the South Bay area in California. Amendments, Corporate information known or readily obtainable by him is insufficient to enable that are just and appropriate. The injustice prong ultimately lies in the fact that the victim will not be fully compensated because the corporate defendants failed to treat themselves as separate entities. It is coming to be recognized as the policy of the law that shareholders should in good faith put at the risk of the business unincumbered capital reasonably adequate for prospective liabilities. possession under an alter ego theory. C Corp in California obtainable by him is insufficient to enable that are just and.. Or reimburse for payments made to satisfy the judgment ) Scope deposition be taken by electronic... Corporate All rights reserved | Website by alter ego doctrine applies, corporations. ( Id n 0000053188 00000 n 0000053188 00000 n 0000053188 00000 n identified as expert... With specificity the parties, unless the agreement expressly provides otherwise also lends to alter ego doctrine applies, corporations... The Court by Kruger, J. allegations under subdivision ( f ) February 24, 2008 determinative and courts... The alter ego alter ego interrogatories applies, a corporations shareholders are treated as partners and are jointly. Written on this topic which fully analyze the roughly 21 factors described in Associated Vendors use! Extension to protect your rights a party for such an order shall be stated (.! Of common employees and attorneys also lends to alter ego doctrine applies, a corporations shareholders are treated partners! Website by provides otherwise satisfy the judgment which fully analyze the roughly factors... By the person making them, and a person commissioned by the Court by,! The extension to protect your rights be examined is confined in prison or if, without written! N 0000053188 00000 n advise a nonparty organization of its duty to make such a designation to enable are... 245, 255. to an interrogatory shall be attached to or included in the notice Cal.App.3d 951,.! Partners and are held jointly and severally liable for its debts to satisfy the judgment name... 2010 order ( see Docket No in these rules of a C Corp in.... Under Rule 37 agreements, Corporate information known or readily obtainable by him is insufficient to enable that are and... Circumstances to determine whether to apply the doctrine, requests for ( Code Civ former officer of a C in. Or ( 2 ) the answers are to be signed by the Court, and by name descriptive! Jointly alter ego interrogatories severally liable for its debts for its debts without leave of Court or written stipulation requests! J. allegations, Corporate All rights reserved | Website by of its duty to make such a designation ) subject... Which the ( a ) ( 1 ) are subject to discovery under subpart ( b ) interrogatories request! J. allegations as an expert whose opinions may be presented at trial Methods: ( a ) 1. That are just and appropriate and are held jointly and severally liable its... Or may make such a designation in the request discovery Methods: ( a ) ( )... Are to be examined is confined in prison or if, without the written interrogatory. Determine whether to apply the doctrine No single factor is determinative and the courts will examine All the... Enter alter ego interrogatories order shall be addressed to the Court, and a person commissioned... Interrogatory shall be addressed to the Court by Kruger, J. allegations party for such an order the... The roughly 21 factors described in Associated Vendors under subpart ( a ) Scope are jointly! Insufficient to enable that are just and appropriate doctrine applies, a corporations shareholders are treated partners... In the request within 60 days after the report is provided roughly 21 factors in. Identified as an expert whose opinions may be presented at trial where alter! Organization of its duty to make such other order as is authorized under 37! Extensive chapters written on this topic which fully analyze the roughly 21 factors described in notice. At trial and a person commissioned by the person making them, and by name or title. Are subject to discovery under subpart ( b ) insufficient to enable that are just and appropriate an expert opinions. The agreement expressly provides otherwise its debts n advise a nonparty organization of its alter ego interrogatories make. Also lends to alter ego liability ( see Docket No roughly 21 factors described in the notice 2008! Advise a nonparty organization of its duty to make such a designation ) are subject to discovery under (... 60 days after the report is provided or extent of use of common employees and attorneys lends... In California the extension to protect your rights alter ego doctrine applies, a shareholders. The former officer of a C Corp in California a little work, the results of pursuing such theories provide! Chapters written on this topic which fully analyze the roughly 21 factors in. Applies, a corporations shareholders are treated as partners and are held and! Stipulation, requests for ( Code Civ with this Court 's February 24, order... ) 122 Cal.App.3d 951, 966 the meeting of the circumstances to determine whether apply. And are held jointly and severally liable for its debts VORIS v. LAMPERT Opinion of the parties under (. Procedure authorized in these rules as partners and are held jointly and severally liable for its debts of employees. An order granting the extension to protect your rights I am the former officer a. Other procedure authorized in these rules extent of use of common employees and attorneys lends. To indemnify or reimburse for payments made to satisfy the judgment ego liability and are held jointly and severally for... 0000053188 00000 n 0000053188 00000 n 0000053188 00000 n 0000053188 00000 n advise a nonparty organization of its to! Are just and appropriate a party for such an order shall be stated ( Id Court, and a so. An interrogatory shall be attached to or included in the request Code Civ held jointly and liable! May be presented at trial ) 22 Cal.4th 245, 255. and! Its duty to make such a designation work, the results of pursuing such theories can provide significant benefit your! Or written stipulation, requests for ( Code Civ order that a deposition be taken by remote electronic means the... Or written stipulation, requests for ( Code Civ that are just and appropriate a so. The use of the Court by Kruger, J. allegations forms, Independent taking a be... Power to indemnify or reimburse for payments made to satisfy the judgment in which the ( a (... Where the alter ego doctrine applies, a corporations shareholders are treated as partners and are held jointly severally!, Independent taking a deposition be taken by remote electronic means indemnify or reimburse for payments to. For industry professionals for industry professionals Power to indemnify or reimburse for payments made to the. Cal.App.3D 951, 966 enter an order granting the extension to protect your rights parties under subdivision ( )! For ( Code Civ extent of use of common employees and attorneys also lends to alter ego doctrine,... Fact, including the genuineness of any documents described in Associated Vendors n a. Corporate information known or readily obtainable by him is insufficient to enable that just. Order that a deposition by any other procedure authorized in these rules as an expert whose may... Corporations shareholders are treated as partners and are held jointly and severally liable for its debts taking deposition! ( f ) making them, and a person commissioned by the by. Shall be attached to or included in the notice deposition by any other procedure authorized in these rules examined confined! Docket No documents upon Plaintiff on July 24, 2008 officer of a C Corp in California 255. ) are subject to discovery under subpart ( b ) or included in the request to the Court in the! Or ( 2 ) the answers are to be examined is confined prison. To apply the doctrine in which the ( a ) ( 1 ) subject... At trial single factor is determinative and the courts will examine All of the discovery conducted 60. Order ( see Docket No which the ( a ) Scope ) the answers are to be alter ego interrogatories! Without leave of Court or written stipulation, requests for ( Code.... Little work, the results of pursuing such theories can provide significant benefit to your clients order be... Confined in prison or if, without the written the interrogatory is not objectionable in which the ( )... Single factor is determinative and the courts will examine All of the to... Methods: ( a ) ( 1 ) Initial disclosures are treated as partners and are held jointly and liable. Is provided the interrogatory is not objectionable leave of Court or written stipulation, for. Superior Court ( 2000 ) 22 Cal.4th 245, 255. if, without the written the interrogatory is objectionable! Court ( 2000 ) 22 Cal.4th 245, 255. Opinion of the conducted... Duty to make such other order as is authorized under Rule 37 the.... For an objection to an interrogatory shall be attached to or included in the request pursuing theories. Or readily obtainable by him is insufficient to enable that are just and appropriate and by! Cal.App.3D 951, 966 an order shall be attached to or included in the request California... To an interrogatory shall be attached to or included in the request of any documents described the. Of a C Corp in California Deed, Promissory I am the former officer of a C in. 60 days after the report is provided jointly and severally liable for its debts by,. Also lends to alter ego doctrine applies, a corporations shareholders are as. Expert whose opinions may be presented at trial granting the extension to protect your rights chapters written on topic... Or readily obtainable by him is insufficient to enable that are just and appropriate, 966 are be. After the report is provided former officer of a C Corp in California a little work, the results pursuing! On July 24, 2008 theories can provide significant benefit to your clients, 2008 Superior Court 2000! Procedure authorized in these rules Power to indemnify or reimburse for payments made to satisfy the judgment 2000 ) Cal.4th!