What is an Informal Discovery Conference?

Informal resolution of discovery disputes is a centerpiece of California civil practice, requiring civil litigants to make “a serious attempt to obtain an informal resolution of each issue.” (Code of Civ. Proc., § 2025(o).)

This rule is designed “to encourage the parties to work out their differences informally so as to avoid the necessity for a formal order.” (McElhaney v. Cessna Aircraft Co. (1982) 134 Cal.App.3d 285, 289, 184 Cal.Rptr. 547.) “This, in turn, will lessen the burden on the court and reduce the unnecessary expenditure of resources by litigants through promotion of informal, extrajudicial resolution of discovery disputes.” (Townsend v. Super. Ct. (1998) 61 Cal.App.4th 1431, 1435.)

Legal Standard

The Legislature passed AB 383, which adds Section 2016.080 to the Code of Civil Procedure, effective January 1, 2018. According to this section, “[i]f an informal resolution is not reached by the parties, as described in Section 2016.040, the court may conduct an informal discovery conference upon request by a party or on the court's own motion for the purpose of discussing discovery matters in dispute between the parties.” (Code of Civ. Proc., § 2016.080(a).)

A determination of whether an attempt at informal resolution is adequate involves the exercise of discretion. (Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1012-1013.) Among the factors the court should consider are the history of the litigation, the nature of the interaction between counsel, the nature of the issues, the type and scope of discovery requested, and the prospects for success. (Id.) A trial judge's perceptions on such matters, inherently factual in nature at least in part, must not be lightly disturbed. (Id.)

Timelines

“If an informal discovery conference is granted or ordered, the court may toll the deadline for filing a discovery motion.” (Code of Civ. Proc., § 2016.080(c)(2).)

Useful Resources for Informal Discovery Conference

Recent Rulings on Informal Discovery Conference

SEAN PERKIN, ET AL. VS CALIFORNIA FAIR PLAN ASSOCIATION

If the parties experience difficulties with discovery, the court requires, at a minimum, telephonic meet and confer, and then prefers the parties set an Informal Discovery Conference before filing a motion to compel. If there is a complete failure to respond at all to propounded discovery, the court requires telephonic contact with opposing counsel to find out status of the discovery responses before filing a motion to compel and a declaration reporting on what occurred during that meet and confer.

  • Hearing

    Feb 01, 2021

  • Type

    Insurance

  • Sub Type

    Intellectual Property

FARHAD NAZARIAN VS JOHARI MOHSEN, ET AL.

On 11/3/20, the parties participated in an Informal Discovery Conference; however, the matter was not resolved. American Pacific now moves to compel further responses to the form interrogatories and RPDs. Form Interrogatories American Pacific moves to compel further responses to form interrogatories, set one, Nos. 6.4, 6.5, 6.7, 8.8. 9.1, 10.1, and 20.8.

  • Hearing

    Jan 28, 2021

NEW MILLENNIUM BUSINESS CONSULTANTS, INC. VS MYMAIL MANAGEMENT, LLC, ET AL.

The Court orders the parties to attend an informal discovery conference prior to ruling on this motion. (See Department 34 Trial Orders, part VII(B).) The Court orders the parties contact Department 34’s judicial assistant, Reyna Navarro, at (213) 633-0154 to schedule this informal discovery conference. Alternatively, the parties can address these issues at the Informal Discovery Conference that is currently scheduled for January 28, 2021.

  • Hearing

    Jan 28, 2021

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

KOREAN AMERICAN CHAMBER OF COMMERCE USA VS DAVID KANG, ET AL.

The parties partook in an informal discovery conference with the court on September 4, 2019. (Id. ¶ 8.) On September 12, 2019, Defendants produced a number of records. (Id. ¶ 9.) After review thereof, Plaintiff’s counsel inquired as to whether Defendant produced all records in their possession and control. (Id.) Defendants responded that they had produced “all of the documents and records the defendants could find after they did their best effort in searching.” (Id., Exh. 3.)

  • Hearing

    Jan 27, 2021

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

RUBIO VS IMPERIAL IRRIGATION DISTRICT

., appearance to be via WebEx absent further notice of the Court, and will be heard on that date if the issues presented are not resolved by the Informal Discovery Conference. In order to conduct the Informal Discovery Conference, the Court orders counsel to provide the Court with the following information: a. Contact information for all counsel who will be participating in the discovery conference, including email address and telephone number.

  • Hearing

    Jan 27, 2021

ZHOIE PEREZ, AN INDIVIDUAL VS EDDUIN ZELAYA GRUNFELD, AN INDIVIDUAL, ET AL.

Plaintiff’s sole argument in the opposition is that the Motion should be denied because Moving Defendant’s counsel has failed to comply with the Court’s standing order that requires an Informal Discovery Conference (“IDC”) prior to the filing of discovery motions. To the extent that Plaintiff failed to oppose arguments raised in the moving papers, the Court finds that Plaintiff has conceded to such arguments under Moulton Niguel Water Dist. v. Colombo (2003) 111 Cal.App.4th 1210, 1215.

  • Hearing

    Jan 26, 2021

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

MOZGHAN JAFARKHANI ET AL VS BRYAN JOSEPH GOMEZ ET AL

The parties are ordered to participate in an Informal Discovery Conference (“IDC”) as required by the Court’s First Amended Standing Order Re: PI Court Procedures (2/24/20), which is available on the LA Superior Court’s website, under the Personal Injury section. The hearing on the MTCF is continued to February 18, 2021 at 10:00 a.m. in Department 27 of the Spring Street Courthouse.

  • Hearing

    Jan 26, 2021

CAROLINE SIMPSON VS SAINT JOAN OF ARC CATHOLIC CHURCH

The parties are ordered to participate in an Informal Discovery Conference (“IDC”) as required by the Court’s Standing Order Re: PI Court Procedures, which is available on the LA Superior Court’s website, under the Personal Injury section. The court notes there is an IDC reserved for 3/08/21. The parties are ordered to participate in the IDC as required by the Court’s Standing Order Re: PI Court Procedures.

  • Hearing

    Jan 25, 2021

BAHRAM JARIDIAN VS SUBARU OF AMERICA, INC., ET AL.

The Court orders the parties contact Department 34’s judicial assistant, Reyna Navarro, at (213) 633-0154 to schedule this informal discovery conference.

  • Hearing

    Jan 25, 2021

BARRERA VS HELLING

The court is available for an informal discovery conference to discuss issues with counsel.

  • Hearing

    Jan 25, 2021

TURMEL WOODS VS CITY OF COMPTON, A MUNICIPALITY

Moreover, the Court also rejects Plaintiff’s argument that Defendant did not request an Informal Discovery Conference (“IDC”) in accordance with Department 56 Rules. An IDC is only required before filing a motion to compel further responses. A party may move for an order compelling a response to interrogatories if the party to whom the interrogatories are directed fails to serve a timely response. (Code Civ. Proc. § 2030.290(b).)

  • Hearing

    Jan 22, 2021

  • Type

    Employment

  • Sub Type

    Wrongful Term

GRICEL LUNA GOMEZ VS KAREN GALSTYAN, ET AL.

The parties are ordered to participate in an Informal Discovery Conference (“IDC”) as required by the Court’s Standing Order Re: PI Court Procedures, which is available on the LA Superior Court’s website, under the Personal Injury section. The hearing on the MTCF is continued to __________________ 10:00 a.m. in Department 31 of the Spring Street Courthouse.

  • Hearing

    Jan 22, 2021

DAVID ALVAREZ VS FRANCISCO DIAZ

However, no informal discovery conference (“IDC”) has been held as to the discovery at issue. The parties are reminded that this court requires an IDC prior to the filing of discovery motions to resolve any issues the parties are unable to resolve on their own. (See Code Civ. Proc. § 2016.080, subd. (a).) The instant motion presents issues that the parties should be able to resolve on their own through good faith meet and confer efforts or with the court’s guidance in an IDC.

  • Hearing

    Jan 22, 2021

  • Type

    Employment

  • Sub Type

    Other Employment

YUANJIN HU , ET AL. VS ISMAEL MUNOZ, ET AL.

The parties are ordered to participate in an Informal Discovery Conference (“IDC”) as required by the Court’s Standing Order Re: PI Court Procedures, which is available on the LA Superior Court’s website, under the Personal Injury section. The court notes an IDC has been reserved for 2/24/21 and 2/25/21. The parties are ordered to participate in the IDC as required by the Court’s Standing Order Re: PI Court Procedures.

  • Hearing

    Jan 22, 2021

RICHMOND COMPASSIONATE VS RICH

An Informal Discovery Conference with the Court did not resolve the issues. In this case, plaintiff alleges that defendants, operators of cannabis dispensaries in Richmond, unlawfully conspired to prevent it from opening a competing dispensary in Richmond. As to damages, it seeks “lost profits.” Even for a for-profit business, a business with no track record faces a difficult task in trying to prove lost profits without undue speculation. (Resort Video, Ltd. v.

  • Hearing

    Jan 21, 2021

SHAW/PARRA VS. BEVERAGES & MORE

The motion for leave to amend, the informal discovery conference, and the further case management conference are dropped from calendar, subject to being reset if plaintiffs’ petition for coordination is denied. During the stay, defendant’s counsel shall keep plaintiffs’ counsel timely advised of any proceeding in the Paez action that might arguably result in a bar to plaintiffs’ claims in this stayed action.

  • Hearing

    Jan 21, 2021

JOYCE ALLEN VS STAPLES, INC., A DELAWARE CORPORATION, ET AL.

On July 25, 2019, in response to a protective order Defendants Staples Inc. and Staples Contract & Commercial, LLC filed against Plaintiff and her special interrogatories, the Court ordered the parties to meet and confer regarding the special interrogatories and then schedule an informal discovery conference with the Court if necessary. On October 17, 2019, the Court granted Plaintiff’s seven motions to compel discovery.

  • Hearing

    Jan 21, 2021

  • Type

    Employment

  • Sub Type

    Discrimination/Harass

BOONE V. ELITE INTEGRITY, LLC

However, it does not appear that the parties are pursuing/defending them in light of the informal discovery conference. The matter is OFF CALENDAR.

  • Hearing

    Jan 21, 2021

(NO CASE NAME AVAILABLE)

On July 25, 2019, in response to a protective order Defendants Staples Inc. and Staples Contract & Commercial, LLC filed against Plaintiff and her special interrogatories, the Court ordered the parties to meet and confer regarding the special interrogatories and then schedule an informal discovery conference with the Court if necessary. On October 17, 2019, the Court granted Plaintiff’s seven motions to compel discovery.

  • Hearing

    Jan 21, 2021

DAVID ALVAREZ VS FRANCISCO DIAZ

However, no informal discovery conference (“IDC”) has been held as to the discovery at issue. The parties are reminded that this court requires an IDC prior to the filing of discovery motions to resolve any issues the parties are unable to resolve on their own. (See Code Civ. Proc. § 2016.080, subd. (a).) The instant motion presents issues that the parties should be able to resolve on their own through good faith meet and confer efforts or with the court’s guidance in an IDC.

  • Hearing

    Jan 20, 2021

  • Type

    Employment

  • Sub Type

    Other Employment

TIMOTHY BURTON VS COSTCO WHOLESALE CORPORATION, ET AL.

On January 7, 2021, Plaintiff filed the declaration of his counsel, Mahsa Farid, who noted the November 30, 2020 Informal Discovery Conference did not involve the issues raised in this motion to compel responses to the form interrogatories. Trial is set for May 3, 2021. PARTY’S REQUESTS Plaintiff moves the Court for an order compelling Defendant Costco to provide responses to Form Interrogatories, Set One, served on December 9, 2019.

  • Hearing

    Jan 20, 2021

JULIE VERNER VS AMERICAN BUSINESS BANK, ET AL.

Only after an informal discovery conference with the parties will the court turn to Cross-Complainant/Defendants American Business Bank, Leon Blankstein, and Wes Schaeffer’s Motion for Appointment of a Discovery Referee and Plaintiff Julie Verner’s Ex Parte Application to Advance 12 Motions to Compel Further Responses.

  • Hearing

    Jan 20, 2021

  • Type

    Employment

  • Sub Type

    Wrongful Term

  • Judge Elaine Lu
  • County

    Los Angeles County, CA

RANDY HALL V. DARREN DORSEY, SR., ET AL.

In addition, the court schedules on its own motion an Informal Discovery Conference to take place via Zoom on January 7, 2021 at 1:30 P.M. (Code Civ. Proc., § 2016.080.) Join Zoom Meeting https://solano-courts-ca- gov.zoom.us/j/87863767264?

  • Hearing

    Jan 20, 2021

TOBIN LANZETTA VS VOLKSWAGEN GROUP OF AMERICA

The Court notes that after the initial motion was filed, the parties engaged in an informal discovery conference and further meet and confer efforts. Defendant served further responses on December 2, 2020. However, the further responses do not fully comply with CCP § 2031.210 to CCP § 2031.240. Defendant does not specifically state that it is complying in full, or in part.

  • Hearing

    Jan 20, 2021

MIGUEL ANGEL HUERTA VS CURT VAN SCHULTZ, ET AL.

An Informal Discovery Conference (“IDC”) was set for 12/23/20; however, the matter was not resolved due to Plaintiff’s unexplained failure to file any form and failure to attend the IDC. Defendants now move to compel further responses to form interrogatories Nos. 2.7, 10.1, 11.2, 12.4 and 20.3, and to RPDs Nos. 4-5 and 9.

  • Hearing

    Jan 19, 2021

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