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. References. Los Angeles, California Commercial Litigation (310) 286-2000. If you wish to keep the information in your envelope between pages, Rule 3.1345 amended effective January 1, 2020; adopted as rule 335 effective January 1, 1984; previously amended effective July 1, 1987, January 1, 1992, January 1, 1997, and July 1, 2001; previously amended and renumbered as rule 3.1020 effective January 1, 2007; previously renumbered as rule 3.3145 effective January 1, 2009. Remember a title. I have reviewed the 8 documents and the attached Declaration of Gregory S. Vistnes and determined that the 8 documents should be withheld under a claim of intragovernmental deliberative process privilege. Specifically, all selections of statistics and data contained within those documents reflect the opinions and judgment of staff of the Antitrust Division as to matters appropriate for consideration during the deliberations regarding the Policy Statements before they were issued. Ct. (1980) 111 Cal.App.3d 902, 905-906.) 1992). 3 (Code of Civ. Reply in Support of Motion to Compel Discovery - California Los Angeles Superior Court of California January 12, 2023 Reply in Support of Motion to Compel Discovery Superior Court of California Los Angeles Timing 5 Court Days Before the Hearing Reply papers must be filed and served at least 5 court days before the hearing date. (6) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document. Discovery should not be permitted under these circumstances. We understand defendants agree that their motion is moot in light of this contemplated discovery. Your recipients will receive an email with this envelope shortly and Miscellaneous Document Filed - SEPARATE STATEMENT FILED. try clicking the minimize button instead. The paper textually cites statistical information to support the analysis and refers to attached maps to support its analysis. We have notified your account executive who will contact you shortly. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Exhibit 2. Proc., 2030.290(a), 2031.300(a).) Defendant filed oppositions on February 10, 2020. (Subd (b) amended effective January 1, 2020; adopted effective July 1, 2001.). Check your previous documents filed in the case and follow the formatting. 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." (BP Alaska Exploration, Inc. v. Super. (4), The Declaration and Claim for Privilege establishes that all nine documents on the Confidential Schedule fall squarely within the deliberative process privilege. MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS Defendants have moved for the Court to compel production, among other documents, of all tabulations, accumulations of data, and other statistical or numerical information relating to the safety zone for hospital mergers contained in the Policy Statements. Defendants have limited Request 13 from its previously broad scope. If you have a lawyer, then the motion was served on your lawyer. 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. By signing up you are agreeing to receive emails according to our privacy policy. Your content views addon has successfully been added. A critical but often neglected (or haphazardly prepared) document which is necessary when making a motion to compel further responses to written discovery is the "separate statement" which is required under Rule 3.1345 of the California Rules of Court. On July 20, 2022 a quiet title - real property case was filed The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following: (1) The text of the request, interrogatory, question, or inspection demand; (2) The text of each response, answer, or objection, and any further responses or answers; (3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; (4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; (5) If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and. Scope, Purpose and Construction. 1000 Failure to timely respond waives all objections, including privilege and work product. 7 Signed this ______________ day of August, 1994. 1000 1986) (rejecting request for discovery). This sort of motion most commonly deals with discovery disputes, when a party who has propounded discovery to either the opposing party or a third party believes that the discovery responses are insufficient. (2) Defendants now seek three categories of documents related to the safety zone for certain hospital mergers set forth in the Policy Statements: (1)Senior Officials' Communications; (2)"Post-decisional" documents which reflect "summaries, comments, investigations, explanations, interpretations, applications, analysis or implementation of" the safety zones; and (3)Numerical data and tabulations. I have reviewed Confidential Schedule of Documents to Declaration and Claim of Privilege of Robert E. Litan. On April 6, 2020, Defendant filed Requests for Jud Case Number: Please wait a moment while we load this page. TENTATIVE RULING: Do your real argument here. Although Rule 3.1345 of the California Rules of Court does not explicitly provide a remedy for failure to comply with it, at least one appellate court has cited with approval the trial courts dropping of a motion to compel discovery where the moving part failed to comply with Rule 335, which was renumbered as Rule 3.1345. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. . If you wish to keep the information in your envelope between pages, (Cal. The separate statement must include--for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested--the following: (Cal. TENTATIVE RULING: In accordance with Fed. Defendant. If the judge is more interested in one issue than another, you can lead off with that issue when it is your turn to speak. This article has been viewed 16,054 times. 8 As soon as you receive this motion, read it carefully. For the foregoing reasons, the United States respectfully requests that the Court deny Defendants' Motion To Compel. In Pacific Molasses Co. v. NLRB, 577 F.2d 1172, 1183 (5th Cir. will be able to access it on trellis. for Prod. Proc., 2025.450(b)(2), 2030.300(b), 2031.310(b). "I have always been interested in law and the specifics of court proceedings. 5 SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. Ct. (1988) 206 Cal.App.3d 632, 636.) The separate statement is the keystone of the opposition No document is more important in opposing summary judgment than the Separate Statement. Your subscription has successfully been upgraded. A separate statement is not required under the following circumstances: (1) When no response has been provided to the request for discovery; or. As soon as you receive this motion, read it carefully. This is a good sample of separate statement required for bringing motion to compel further responses. There are 10 references cited in this article, which can be found at the bottom of the page. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories Proc., 2031.300(a).) II. The sample has been revised and updated in March 2018, is 14 pages and includes, (CCP 2030.300, 2031.310) Separate Statement of Items in Dispute. If the requested information wasnt relevant, then you might not feel they are entitled to it. "The policy statements give health care providers guidance in the form of 'antitrust safety zones,' which describe the circumstances under which the Agencies will not challenge conduct as violative of the antitrust laws as a matter of prosecutorial discretion." Stephen J. Rapp United States Attorney, By:_______________________________ Lawrence D. Kudej Assistant United States Attorney Northern District of Iowa P.O. M As to Requests 4 and 7, defendants have in correspondence and their moving papers limited the original requests to documents on which an expert witness relies in forming the expert's report, thereby meeting the United States' objections. 4. You have actually complied with the discovery request. Defendants would have this Court sanction a line of discovery (and presumably a later line of evidence and argument) that are irrelevant to the key issue the Court must ultimately decide in this lawsuit: whether the defendants' proposed "partnership" is legal or not under applicable antitrust principles and precedent. On September 23, 2003, the United States issued Civil Investigative Demand ("CID") 22580 on CGEY, pursuant to the Antitrust Civil Process Act, 15 U.S.C. ), The separate statement is a very useful tool for the Court to decide discovery disputes; it requires that the dispute be presented on a request-by-request basis with the objections, responses and arguments all in one place. The Antitrust Division has referred that document to the FTC for its evaluation of whether it is privileged. (Code of Civ. Defendants did not respond. In other words, defendants seek, in essence, to challenge the government's exercise of prosecutorial discretion in bringing this case. may be governed by the Code of Civil Procedure ("C.C.P."), the California Rules of Court ("C.R.C."), local court rules, or all three. Attorney For The Defendant, Nrt West, Inc, Dba Coldwell Banker Residential Your subscription was successfully upgraded. This article was co-authored by Clinton M. Sandvick, JD, PhD. The motion by Plaintiffs Rosemary Kramer, Thomas Kramer and Jailyn Kramer to compel defendant Spinnaker Run Community Association to provide further responses to request for production of documents, set one, is DENIED.. With respect to motions to compel further responses to requests for production of documents, Code Civ. Ballesteros, Daniel Walter, aj tng ca`pigtg lkigs fjd, rgcards al tnks fctkaj! Exhibit 1 at 1. These documents reflect the deliberations, considerations, analyses, and recommendations of Antitrust Division staff and officials concerning the enforcement of the antitrust laws. Sample language could read: Defendant opposes Plaintiffs Motion for an Order To Compel on the grounds that (1) the documents requested are not relevant to the lawsuit and (2) certain relevant documents are protected from disclosure by the attorney-client privilege., For example, if you are refusing to turn documents over because they are not relevant, then remind the court of the rules regarding relevancy: Rule 26(b)(1) limits discovery to any non-privileged matter that is relevant to any partys claim or defense. If a party wants broader discovery, then it must show good cause to support the request. Deft's Form Interrog (Set 1) to Eric Hvolboll/Req. Bellings, David, If these officials and staff anticipate subsequent disclosure and inquisition regarding their views, they will be inclined to temper candor and to restrict advice with resulting detriment to the policy-making process, enforcement of the antitrust laws, and the public interest. Given the expedited briefing schedule on this issue, and the lack of relevance in any event of the document, we ask the Court's indulgence with regard to this document. The draft was never finalized or adopted as a statement of the Antitrust Division. 7 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF IOWA EASTERN DIVISION, OPPOSITION TO DEFENDANTS' MOTION FOR ORDER TO COMPEL THE PRODUCTION OF DOCUMENTS FROM PLAINTIFF. This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are objectionable in that the documents requested clearly do not relate to the claim or defense of the party seeking discovery or of any other party to the action as required by Code of Civil Procedure 2017.010, and on the further grounds that the requests for production of document are unduly burdensome and oppressive in that the particular documents requests are not specifically described and the categories are not particularized as required by California law, and that the moving party failed to make a reasonable effort to meet and confer. Code Civ. Defendants cite two cases regarding production of factual material which do not apply to the facts of this case. A sample "meet and . Last. CAR has filed an. Attorney For The Defendant, England, Elizabeth Anne One of the primary responsibilities of the Antitrust Division is to detect and prosecute violations of the federal antitrust laws. Does 1 Through 20 Inclusive, ), 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. MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION We will email you United States v. Jacob, 781 F.2d 643, 646-47 (8th Cir. Exhibit 3 resolves defendants' procedural arguments regarding invocation of the privilege. at 1-2 (emphasis supplied). The Motions were originally set to be heard on March 4, 2020. Therefore, Plaintiffs respectfully request that this Court deny Defendant's Motion to Compel Arbitration and Stay Proceedings ("Motion"). 1978), the NLRB had compiled a "statistical report which contains no subjective conclusions, and, as a result, must be considered 'purely factual' in nature." The report was not part of a deliberative process, such as that involved in developing the Policy Statements at issue here. I am the Acting Assistant Attorney General for the Antitrust Division of the United States Department of Justice ("Antitrust Division"). The eight documents referred to in paragraph 3 above reflect the deliberative processes of the Antitrust Division. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. California Code of Civil Procedure (CCP) 2016.040. The first safety zone applies to hospital mergers satisfying certain criteria. 4 "G,*X+%G" &2X 'XG TG *'TG2X+G, 2L "2*(G&T, "ng Appasktkaj snfii hg hfsgd aj tnks Appasktkaj! by clicking the Inbox on the top right hand corner. R. Civ. Id. The separate statement requirement was designed to streamline adjudication of discovery motions, and a failure to file a separate statement is a sufficient basis for denying plaintiffs motion to compel. You can always see your envelopes Motion to Compel - a request that the court order a party to the legal action to do something, which has previously been ordered, or which is within the bounds of normal procedure Filing a Motion While a motion may, in some instances, be made orally during a trial or hearing, a motion generally must be made through a set of written documents. Apply the facts of your case to show why the information you are seeking is discoverable. The staff selected for inclusion in the documents all tables, maps and other statistical or numerical information. 1993). This is the most important document of your motion and the first document that a court will rely on. Consultants (2007) 148 Cal.App.4th 390, 405.). A 21-page draft September 13, 1993 set of Questions and Answers regarding hospital mergers and other issues. On October 31, 2018, default was entered against Centinela. VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord, Amit Lal et al. 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. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. They were created during the prosecutorial and policy deliberations leading up to publication of the Policy Statements and safety zones. England, Elizabeth Anne, EPA v. Mink, 410 U.S. 73, 93 (1972) (recognizing that the court should guard against eroding the purposes of the privilege during the process of evaluating its applicability). Dept: ", http://www.clearinghouse.net/chDocs/public/PN-GA-0003-0003.pdf, http://www.nolo.com/legal-encyclopedia/formal-discovery-gathering-evidence-lawsuit-29764.html, https://www.justice.gov/atr/case-document/opposition-defendants-motion-compel-production-documents-plaintiffs, http://www.citizen.org/documents/wages-v-lin-opposition-to-motion-to-compel.pdf, https://www.law.cornell.edu/rules/frcp/rule_5, http://saclaw.org/wp-content/uploads/sbs-motion-to-compel-discovery-responses.pdf, https://www.bestlawyers.com/Article/effective-oral-argument/26/, http://www.rcfp.org/north-carolina-privilege-compendium/1-interlocutory-appeals. Last Updated: January 22, 2022 Brockway v. Dep't of Air Force, 518 F.2d 1184, 1193 (8th Cir. 3 STATEMENT OF FACTS On February 14, 2018, Plaintiffs and Defendant entered into a written contract ("Contract") whereby Defendant agreed to furnish certain labor, services, equipment and . NLRB v. Sears, Roebuck & Co., 421 U.S. 132, 138 (1974). The maps analyze the geographic distribution of hospitals of certain sizes. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (5) To compel or to quash the production of documents or tangible things at a deposition; (6) For medical examination over objection; and, (Subd (a) amended effective January 1, 2007; previously amended effective July 1, 1987, January 1, 1992, January 1, 1997, and July 1, 2001.). 9 Read all of the motions. II. represented by I am an economist with the Antitrust Division of the Department of Justice. will be able to access it on trellis. Wayne v. United States, 470 U.S. 598, 607 (1985). You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. (2) When a court has allowed the moving party to submit-in place of a separate statement-a concise outline of the discovery request and each response in dispute. 10 Rules of Ct., Rule 3.1345(c).) Background Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. The motion to compel is used to ask the court to order the non-complying party . Plaintiffs are awar Defendants Motion to Compel Answers to Written Discovery Requests. These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. Your recipients will receive an email with this envelope shortly and Couns., Inc. v. Pac. Over a period of 8 months, Sundance filed a motion to dismiss, filed an answer, and engaged in mediation, before moving to compel arbitration. But the court allowed the late motion to compel if the moving party undertook some steps. ANALYSIS: For example, if you are a journalist, then you might have a statutory privilege not to be compelled to release the sources of your information. SC129356 You cant respond to a request that you dont understand. 1992), the data at issue was census data, not factual information gathered and analyzed by governmental officials during the course of their deliberations. Motion ..quest is evasive or incomplete. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; ), The statute contains no time limit for a motion to compel where no responses have been served. What Is a Separate Statement in Discovery Motions? Defendants' Memorandum In Support at 9-11. You will lose the information in your envelope. . "The court shall impose a monetary sanction. Case No. (Code Civ. Ct. (1988) 199 Cal.App.3d 1240, 1270.) TENTATIVE RULING: Each of defendants four motions to compel further discovery responses is denied for failure to comply with Rule 3.1345 of the California Rules of Court regarding the format of discovery motions. The paper also discusses and refers to an attached table from a publication that summarizes and comments on other published cost studies. vs City of Escalon et al. However, if one side refuses to comply with a discovery request, then the party who made the request can file a Motion to Compel with the court. ), 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. However, it is not important to draft the separate for Sanctions; to Deft's Req. by CASE NO. Sundance did not initially move to compel arbitration or stay the case. Fed. 1746, I certify under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief. (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. The factual discussion in that draft document is intertwined with the staff's reasoning and advice, was not disseminated to the public, and was not adopted as an official explanation. Dept. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not relevant to this (CCP 2030.300) tng dgcifrftkaj al QQQQQQQQQQQfjd g#nkhkts fttfcngd tngrgta! This article has been viewed 16,054 times. : C16 Complaint Filed: December 3, 2014 Trial Date: May 8, 2017 DEFENDANT'S OPPOSITION TO PLAINTIFF'S . If the consumer/employee objects or files a motion to quash, the witness is not permitted to respond to your Deposition Subpoena.You may make a Motion to Compel Production (deadline: 20 days after service of the . Be detailed in the law as to why the objections are garbage. Xg`g`hgr tnft )2X 2##2,+T+2&, pgrsajfi dgikvgry ar avgrjkmnt `fki. Contributor Robin Mashal Los Angeles, California Commercial Litigation (310) 286-2000 About I am a litigation lawyer, licensed to practice law in the State of California. Rapp United States Attorney Northern District of Iowa P.O moving party undertook some steps, Dba Banker... Miscellaneous document filed - separate statement is the keystone of the privilege your account who... Was entered against Centinela comments on other published cost studies January 1, 2001. ). )..! The policy Statements and safety zones economist with the Antitrust Division Sanctions ; to deft 's Req and... Commercial Litigation ( 310 ) 286-2000 of court proceedings, 1183 ( 5th Cir found at the bottom of Antitrust... Have always been interested in law and the first safety zone applies to hospital mergers and issues...: Please wait a moment while opposition to motion to compel california separate statement load this page but the court shall impose a monetary.! 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