§Why CasetextPricing

Separate Statement In Support of Motion To Compel Further Responses To Deposition Subpoena For Personal Appearance And Production of Documents And Things

Response

7 Cited authorities

  1. Mitchell v. Superior Court

    37 Cal.3d 591 (Cal. 1984)   Cited 147 times   2 Legal Analyses
    Recognizing that privilege may be waived in " ' one situation in which a client has placed in issue the decisions, conclusions, and mental state of the attorney who will be called as a witness to prove such matters' "

  2. Southern Cal. Gas Co. v. Public Utilities Com.

    50 Cal.3d 31 (Cal. 1990)   Cited 65 times
    Finding that counsel's actual legal analysis was not essential to the case, explaining that the reasonableness issue was "an objective one which [did] not depend on a particular attorney's analysis, but upon the terms of the contract itself and surrounding factual circumstances"

  3. Merritt v. Superior Court

    9 Cal.App.3d 721 (Cal. Ct. App. 1970)   Cited 31 times
    In Merritt, where plaintiff asserted a bad faith claim against an insurer, the court "held that plaintiff had impliedly waived his privilege since he had specifically put the state of mind of his attorney at issue by alleging that the defendant's attorney had confused his attorney and impeded his attorney's ability to settle his claim."

  4. Julrik Productions, Inc. v. Chester

    38 Cal.App.3d 807 (Cal. Ct. App. 1974)   Cited 4 times
    Finding trial court did not error in accepting testimony why plaintiff did not question defendant's statements in a letter and concluding that the letter did not show that plaintiff could not have reasonably relied upon defendant's statements

  5. Rule 5 - Serving and Filing Pleadings and Other Papers

    Fed. R. Civ. P. 5   Cited 22,753 times   16 Legal Analyses
    Allowing service by filing papers with the court's electronic-filing system

  6. Section 2018.030 - Generally

    Cal. Code Civ. Proc. § 2018.030   Cited 100 times   7 Legal Analyses

    (a) A writing that reflects an attorney's impressions, conclusions, opinions, or legal research or theories is not discoverable under any circumstances. (b) The work product of an attorney, other than a writing described in subdivision (a), is not discoverable unless the court determines that denial of discovery will unfairly prejudice the party seeking discovery in preparing that party's claim or defense or will result in an injustice. Ca. Civ. Proc. Code § 2018.030 Added by Stats 2004 ch 182 (AB

  7. Rule 3.1345 - Format of discovery motions

    Cal. R. 3.1345   Cited 34 times

    (a) Separate statement required Except as provided in (b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. 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; (4) To compel answers at a deposition;