A motion concerning interrogatories, inspection demands, or admission requests must identify the interrogatories, demands, or requests by set and number. There probably wont be time to argue much more. 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. Include your email address to get a message when this question is answered. Your subscription has successfully been upgraded. 8 The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. Interrogatories Despite these facts, defendants seek the documents in order purportedly to identify the "reasons" for the safety zone, apparently in the hope of questioning the government's choice of safety zone standards that, on their face, exclude defendants' hospitals. A similar document, not described in the Confidential Schedule, was prepared by the Federal Trade Commission ("FTC"). They were developed by staff attorneys and economists of the Antitrust Division of the Justice Department solely to aid the Assistant Attorney General in charge of that Division in deliberating on the question of whether to develop a safety zone for hospital mergers and to decide the standard for that safety zone. California Code of Civil Procedure (CCP) 2016.040. The FTC, an independent agency, should be given the opportunity to review the document for privilege or other grounds for nondisclosure, in the event the Court were to rule that these documents are otherwise within the scope of permissible discovery. In short, the document was part of the deliberative process. Dept. Brian Leung v. Alireza Alivandivafa 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. The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel. On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. 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 action (nor likely to lead to the discovery of admissible evidence) and, in any event, are protected from discovery by the intragovernmental deliberative process privilege. Policarpa Cavadia et al. The parties have identified expert witnesses and agreed to a timetable for exchange of expert reports. 8 During a lawsuit, each side can request information and documents from each other. 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. If you have a lawyer, then the motion was served on your lawyer. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Form Interrogatories, Set O ..Centinela Gas Station, Inc. (Centinela) (collectively, Defendants). Remember a title. Some of the rules are in tension with this holding. MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION (4) Any reply to the opposition shall be served and filed by the moving party not less than five days preceding the noticed or continued date of hearing, unless the court for good cause orders . at 922. Parties may also move to compel further responses as to interrogatories on similar grounds. Defendant. 10 You should limit your argument to your strongest two or three points. R. Civ. We will email you If all else fails, prepare your opposition. Proc., 2030.290(a), 2031.300(a). Discovery should not be permitted under these circumstances. If you wish to keep the information in your envelope between pages, Your alert tracking was successfully added. England, Elizabeth Anne, when new changes related to " are available. The United States may withhold factual information where, as here, its disclosure will expose the author's thinking as to which facts were relevant. Accessing Verdicts requires a change to your plan. Part 1 Drafting Your Motion in Opposition 1 Read the motion to compel. 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. In a brief telephone conference call on August 3, they refused to articulate any grounds for relevance of this category of documents and advised the United States that they would file a Motion To Compel. vs University of the Pacific, a California Corporation et , ORDER DENYING DEFENDANT'S MOTION TO COMPEL FURTHER DISCOVERY RESPONSES UND, JON LOUIS VS. ST FRANCIS BAY -ONE HUNDRED ONE CRESCENT WAY et al, Motion to Compel Further Responses to Special Interrogatorie - From Defend, DOE -V- SAN BERNARDINO CITY UNIFIED SCHOOL Print, MOTION TO COMPEL FILED RECORD SEALED - Plaintiff Mishelle Neverson's Motio. 19.07.28 Separate Statement MTC - Separate Statement, Filed, Filippini Wealth Management Inc vs Max Baril et al, Separate Statement IN SUPPORT OF MOTION TO COMPEL DISCOVERY RESPONSES - Se, THE PEOPLE OF THE STATE CALIFORNIA, et al. SEPARATE STATEMENT OF FORM INTERROGATORIES IN DISPUTE Defendant City of Los Angeles ("City") hereby submits its Separate Statement of Form Interrogatories in Dispute pursuant to California Rule of Court 3.1345. (CCP 2030.300, 2031.310) (Code Civ. Share sensitive information only on official, secure websites. I have determined that disclosure of the advice, opinion, facts, and recommendations contained in those documents would inhibit the frank exchange of information and ideas among Antitrust Division officials and staff in the course of their predecisional deliberations concerning enforcement and policy decisions. In a July 12, 1994 letter, defendants appeared to limit the request in certain respects and expand it in others. Hearing Date: Xg`g`hgr tnft )2X 2##2,+T+2&, pgrsajfi dgikvgry ar avgrjkmnt `fki. Check your previous documents filed in the case and follow the formatting. II. by clicking the Inbox on the top right hand corner. 6. Code Civ. 7 A .gov website belongs to an official government organization in the United States. for Sanctions; to Deft's Req. R. Civ. Ct. (1988) 199 Cal.App.3d 1240, 1270.) . Send the other defendant a copy of your motion. CASE NO. You can always see your envelopes Defendants have moved for an order regarding Document Requests 4, 7, and 13 to which the United States lodged objections. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. Los Angeles, California Commercial Litigation (310) 286-2000. Mink, 410 U.S. at 92. (Code Civ. If you wish to keep the information in your envelope between pages, Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. 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. 2 Separate Statement. A single procedure (e.g., filing a complaint, answering a complaint, filing a motion, opposing a motion, serving discovery, responding to discovery, etc.) Consultants (2007) 148 Cal.App.4th 390, 405.). "I have always been interested in law and the specifics of court proceedings. The first safety zone applies to hospital mergers satisfying certain criteria. Proc., 2023.030(a). The eight documents referred to in paragraph 3 above reflect the deliberative processes of the Antitrust Division. 4. Please wait a moment while we load this page. United States v. Jacob, 781 F.2d 643, 646-47 (8th Cir. The remainder of the document discusses a proposed safety zone other than the one for hospital mergers. This article has been viewed 16,054 times. Proc., 2031.310(c); 2030.300(c). 1000 To date, no reply brief has been filed. Disclosure of the data at issue in that case, in contrast to disclosure of that at issue here, would not have "enable[d] the public to reconstruct any of the protected deliberative process." Therefore, Plaintiffs respectfully request that this Court deny Defendant's Motion to Compel Arbitration and Stay Proceedings ("Motion"). The Antitrust Division has conducted a search of its files and has located nine documents that arguably fall within that category. To the extent there is factual material contained in these documents, the facts were deliberately selected from a great volume of potentially relevant facts; they reflect the thought processes of Antitrust Division staff and officials as to the types of facts relevant to possible prosecutorial decisions and antitrust enforcement policy, and the facts are inextricably intertwined with the authors' analyses and recommendations. Thanks to all authors for creating a page that has been read 16,054 times. Plaintiffs were unable to move to compel attendance at trial in . You can always see your envelopes As demonstrated in the Declaration of Gregory S. Vistnes, which is Exhibit 4 to this Memorandum, all numerical data and tabulations reflect the process of separating significant facts from insignificant ones, Mapother, 3 F.3d at 1398-99. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. Disclosure of the tables, maps, statistics and numerical information would reveal the thinking of staff as to which facts were relevant to the deliberations leading up to issuance of the Policy Statements. Proc., 2030.290(b), 2031.300(b), 2033.280 (a party who fails to serve a timely response to a request for admission); Leach v. Super. April 30, 2021 Please wait a moment while we load this page. Rules of Ct., Rule 3.1345(c).) Proc., 2025.450 (b) (2) .) If the judge asks questions, then stand quietly and dont interrupt the judge. ( Your credits were successfully purchased. Rules of Court, rule 3.13350(e)(2).) ), PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED, Personal Injury Non-Motor Vehicle Unlimited, 1 TENTATIVE RULING: On October 30, 2019, Glassdoor filed its opposition to Payward's motion to compel . The eight documents referred to in paragraph 3 above contain analyses of and recommendations by Antitrust Division economists and attorneys to their superiors during the deliberations leading up to issuance of the Policy Statements. Sample Opposition to Motion to Compel Further Responses to Documents for California, 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 , 100% found this document useful (4 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Supgrkar Caurt al tng Stftg al Cfiklarjkf, Ta suhscrkhg ta `y LXGG wggeiy igmfi jgwsigttgr vkskt, Ta vkgw avgr 3 sf`pig igmfi dacu`gjts said hy !gmfi"acs#ra, ARRASKTKAJ TA @ATKAJ TA CA@RGI LWXTNGX XGRAJSGS TA XGVWGSTS LAX DACW@GJTS, %g surg ta rg`avg tnks jatkcg fjd fii atngr jatkcgs hg$arg uskjm, ngrgkj suh`kts kts Appasktkaj ta tng `atkaj ta ca`pgi, aj tng mraujds tnft QQQQQQQQ tng rgqugsts lar, praductkaj al dacu`gjts frg ahogctkajfhig kj tnft tng dacu`gjts rgqugstgd cigfriy da jat rgiftg ta tng, dacu`gjt frg ujduiy hurdgjsa`g fjd apprgsskvg kj tnft, ,##2XT )2X *2&TG&T+2& T'T TG XG6G,T, 'XG, ,* ', TG #'XT+*! In addition, with the exception of a few tables reproduced from published texts, the staff created all tables and maps from larger publicly-available data bases (1989-90 "Individual Hospital Data," California Healthcare Facilities Commission and the American Hospital Association data set on hospitals). 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. M 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. (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. against Rules of Ct., Rule 3.1345; Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 892-893; Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL for Prod. R. Civ. Plaintiff Nicole Jacksons LLCs (1) Motion To Compel Further Responses To Form Interrogatories, Set One; Request For Monetary Sanctions; and (2) Motion To Compel Further Responses To Requests For Production, Set One; Request For Monetary Sanctio ..s to Compel Further Responses on September 12, 2019. Except as provided in 3.1345(b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Adding your team is easy in the "Manage Company Users" tab. 1746, I certify under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief. 5 Your recipients will receive an email with this envelope shortly and by clicking the Inbox on the top right hand corner. Luther, Robert Stevenson, In support of its opposition, the United States submits this Memorandum, the Declaration and Claim of Privilege of Robert E. Litan, and the Declaration of Gregory S. Vistnes. Proc., Material must not be incorporated into the separate statement by reference. California courts thus have found a waiver of the right to arbitration in a variety of contexts, " ' "ranging from situations in which the party seeking to compel arbitration has previously taken steps inconsistent with an intent to invoke arbitration [citations] to instances in which the petitioning party has unreasonably delayed in . Plaintiff also refiled the Motions on March 25 and 30, 2020 with accompanying declarations and separate statements. You should receive a copy of the other side's motion that was filed with the court. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. "The court shall impose a monetary sanction. ), The court shall impose a monetary sanction 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. (Code Civ. I have reviewed Confidential Schedule of Documents to Declaration and Claim of Privilege of Robert E. Litan. He received his JD from the University of Wisconsin-Madison in 1998 and his PhD in American History from the University of Oregon in 2013. (1) Thus, the documents requested are beyond the scope of discovery, because they are not "relevant to the subject matter involved in the pending action, . Defendants' proposed transaction does not fall within the safety zone for hospital mergers, and defendants have so stipulated. You cant respond to a request that you dont understand. CAR has filed an. (The ninth document is a document of the Federal Trade Commission; therefore the Division has referred that document to the Commission to determine whether it has any privilege to assert regarding its discovery.). For example, you might be one of two defendants. 1. On September 15, 1993, the Antitrust Division joined with the Federal Trade Commission in issuing Statements of Antitrust Enforcement Policy in the Health Care Area ("Policy Statements") regarding "their antitrust enforcement policies regarding mergers and various joint activities in the health care area." Sit in on a discovery hearing. 5. We will email you Maxwell, Judith et al. This is the most important document of your motion and the first document that a court will rely on. when new changes related to " are available. A motion to compel asks the court to order either the opposing party or a third party to take some action. 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. . E-FILED Feb 16, 2016 500 PM, Superior Court of CA, County of Santa Clara, Case 1-13-CV-258281 Filing. (MF)THE ORIGINAL MOWBRAY vs UTILITY TREE Print, NICOLE M -V- MORONGO UNIFIED SCHOOL DISTRICT Print, Proof of Service Filed - Opposition, declarations, separate statement, Hess et al -v- DoubleTree by Hiltonet al Print, Separate Statement of Discovery Items - SSF003, Jin VS Life Chiropractic College West, a California corporat, Separate Statement of Discovery Requests, Discovery Responses Filed - Fili, SEPARATE STATEMENT OF DISPUTED DISCOVERY FILED RECORD SEALED - Separate St. They should be cited as "Civil L.R.___". Providence Journal, 981 F.2d at 562. 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. That the defendants did not plead any defense related to the government's exercise of prosecutorial discretion nor challenge the allegations of the Complaint under Fed. By using our site, you agree to our, {"smallUrl":"https:\/\/www.wikihow.com\/images\/thumb\/d\/db\/Oppose-a-Motion-to-Compel-Step-1.jpg\/v4-460px-Oppose-a-Motion-to-Compel-Step-1.jpg","bigUrl":"\/images\/thumb\/d\/db\/Oppose-a-Motion-to-Compel-Step-1.jpg\/aid7732064-v4-728px-Oppose-a-Motion-to-Compel-Step-1.jpg","smallWidth":460,"smallHeight":345,"bigWidth":728,"bigHeight":546,"licensing":"
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opposition to motion to compel california separate statement