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Reply Reply Memorandum In Support of Motion To Preclude Testimony At Trial Based On Discovery Misconduct Or In The Alternative To Compel Additional Deposition Testimony of Countys Person Most Qualified Pursuant To Cal Civ Proc Section 2025480

Reply

13 Cited authorities

  1. Laabs v. City of Victorville

    163 Cal.App.4th 1242 (Cal. Ct. App. 2008)   Cited 346 times
    Finding no abuse of discretion where the trial court "could have easily concluded that at the time plaintiff refused to admit such matters she reasonably held a good faith belief that she would prevail at trial on these issues"

  2. Hutton v. Fid. Nat'l Title Co.

    213 Cal.App.4th 486 (Cal. Ct. App. 2013)   Cited 114 times   1 Legal Analyses

    F063318/F063922 2013-02-22 Brent HUTTON , Plaintiff and Appellant, v. FIDELITY NATIONAL TITLE COMPANY , Defendant and Respondent. See 12 Witkin, Summary of Cal. Law (10th ed. 2005) Real Property, § 305. APPEAL from a judgment of the Superior Court of Kern County. Sidney P. Chapin, Judge. (Super. Ct. Nos. CV–269732 & CV–269733) Kane See12 Witkin, Summary of Cal. Law (10th ed. 2005) Real Property, § 305. APPEAL from a judgment of the Superior Court of Kern County. Sidney P. Chapin, Judge. (Super. Ct

  3. Nieto v. Blue Shield of California Life & Health Ins. Co.

    181 Cal.App.4th 60 (Cal. Ct. App. 2010)   Cited 122 times   2 Legal Analyses
    Noting that the law's second and third sentences "provide that the consequence of nondelivery following the insured's request is that the application may not be introduced into evidence"

  4. Mercury Interactive v. Klein

    158 Cal.App.4th 60 (Cal. Ct. App. 2007)   Cited 115 times   1 Legal Analyses
    Concluding discovery material was not protected by constitutional right of access and remanding for determination of whether documents should remain confidential under protective order

  5. Jacobs v. Coldwell Banker Residential Brokerage Co.

    14 Cal.App.5th 438 (Cal. Ct. App. 2017)   Cited 58 times
    Noting that complaint stated," 'Plaintiff. . . was lawfully and foreseeably on an outdoor diving board on said premises when the attachments connecting the diving board to the ground broke off causing the board, and Plaintiff, to fall into a nearby empty pool'"

  6. In re Marriage of Heggie

    99 Cal.App.4th 28 (Cal. Ct. App. 2002)   Cited 70 times
    In Heggie, the court found that under section 2123 "where the only reason to set aside a judgment is that it was 'inequitable when made, ' the trial court is affirmatively commanded not to set the judgment aside under 'any' law."

  7. Flagship Theatres of Palm Desert, LLC v. Century Theatres, Inc.

    198 Cal.App.4th 1366 (Cal. Ct. App. 2011)   Cited 26 times
    Noting federal law's antitrust injury requirement applies to claims under the Cartwright Act

  8. Johnson v. Raytheon Co.

    33 Cal.App.5th 617 (Cal. Ct. App. 2019)   Cited 14 times

    B281411 03-08-2019 Laurence JOHNSON, Plaintiff and Appellant, v. The RAYTHEON COMPANY, INC. et al., Defendants and Respondents. Robinson Calcagnie, Mark P. Robinson, Kevin Calcagnie, Newport Beach, Genevieve Outlaw; Steinbrecher and Associates and Edward Steinbrecher for Plaintiff and Appellant. Horvitz & Levy, Mitchell C. Tilner, Stephen E. Norris, Burbank; Burke, Williams & Sorensen, Mark J. Mulkerin, Santa Ana, and Brian Hamblet, Los Angeles, for Defendant and Respondent The Raytheon Company Inc

  9. Glenfed Dev. Corp. v. Superior Court

    53 Cal.App.4th 1113 (Cal. Ct. App. 1997)   Cited 19 times

    Docket No. B108546. March 27, 1997. Appeal from Superior Court of Los Angeles County, No. BC131389, Frances Rothschild, Judge. COUNSEL Cox, Castle Nicholson, Jeffrey D. Masters and Mark Moore for Petitioner. No appearance for Respondent. Horvitz Levy, Peter Abrahams, Andrea M. Gauthier, Murtaugh, Miller, Meyer Nelson, Bradford H. Miller and Gregory M. Heuser for Real Party in Interest. OPINION VOGEL (Miriam A.), J. — BACKGROUND Several lawsuits alleging construction defects were filed against Glenfed

  10. Section 431.30 - General denial; denial made positively or according to information and belief of defendant

    Cal. Code Civ. Proc. § 431.30   Cited 139 times
    Requiring an answer to contain both a general or specific denial of factual allegations, § 431.30(b), and a statement of "any new matter constituting a defense," § 431.30(b)

  11. Section 2025.480 - Motion to compel answer or production

    Cal. Code Civ. Proc. § 2025.480   Cited 55 times
    Authorizing imposition of "an issue sanction, an evidence sanction, or a terminating sanction," but only "[i]f a deponent fails to obey an order" entered by the court in response to a motion to compel

  12. Section 19 - Designation of act

    Cal. Code Civ. Proc. § 19   Cited 35 times

    This Act, whenever cited, enumerated, referred to, or amended, may be designated simply as "The Code of Civil Procedure," adding, when necessary, the number of the section. Ca. Civ. Proc. Code § 19 Enacted 1872.

  13. Rule 3.1113 - Memorandum

    Cal. R. 3.1113   Cited 97 times

    (a) Memorandum in support of motion A party filing a motion, except for a motion listed in rule 3.1114, must serve and file a supporting memorandum. The court may construe the absence of a memorandum as an admission that the motion or special demurrer is not meritorious and cause for its denial and, in the case of a demurrer, as a waiver of all grounds not supported. (b) Contents of memorandum The memorandum must contain a statement of facts, a concise statement of the law, evidence and arguments