What is a Motion to Compel Production of Documents?
The demanding party may move for an order compelling compliance if the responding party “fails to permit the inspection, copying, testing, or sampling in accordance with that party's statement of compliance....” (Code of Civ. Proc. § 2031.320(a); see also Code of Civ. Proc., § 2025.450(a) (“If, after service of a deposition notice, a party to the action... fails to appear for examination, or to proceed with it, or to produce for inspection any document or tangible thing described in the deposition notice, the party giving the notice may move for an order compelling the deponent's attendance and testimony, and the production for inspection of any document or tangible thing described in the deposition notice.”).)
How to Structure the Motion
If a motion seeks to order the deponent to produce documents listed in the deposition notice, then the motion must “set forth specific facts showing good cause justifying the production for inspection of any document, electrically stored information, or tangible thing described in the deposition notice.” (Code Civ. Proc. § 2025.450(b)(1).)
A party demanding the production of document to move for an order to compel further responses if:
a statement of compliance with the demand is incomplete,
a representation of inability to comply is inadequate, incomplete, or evasive, and
an objection in the response is without merit or too general.
...The motion must set forth specific facts showing good cause justifying the discovery sought by the demand.
(Code of Civ. Proc. § 2031.310)
The California Rules of Court do not require the moving party to file a separate statement in connection with the distinct motion under Code of Civil Procedure section 2025.450 to compel the deponent to appear for examination. (Rules of Court, rule 3.1345(a).)
Response
The Code of Civil Procedure, section 2031.260(a) provides that within 30 days after service of a demand for production of documents the party to whom the demand was directed shall serve a written response to the party making the demand. The Code of Civil Procedure, section 2031.250(a) provides that the response shall be verified. Further, the Code of Civil Procedure, section 2031.280(b) requires the party to whom the demand for production was directed to produce the requested documents by the date specified in the demand unless an objection has been made to that date.
Useful Resources for Motion to Compel Production of Documents
# 10. Rodolfo Garcia v. Jose Zepeda, et al.
Case No.: TC028713
Matter on calendar for: motion to compel further and sanctions
Tentative ruling:
I. Background
Plaintiffs are tenants alleging habitability issues. Defendant Samuel Mikhail brings several motions:
1) Motion to compel responses to form interrogatories, Set One;
· This is against plaintiffs Daniel Valdivia, Daisey Robles, and Vict...
..nst Maria Saenz
Plaintiff’s counsel failed to appear at the informal discovery conference. Mikhail seeks $3,310 in discovery sanctions. The opposition was due on October 30, 2018, but was filed on November 2, 2018 and is late.
For the reasons set forth below, the Court grants the motion in part.
II. Standard
a. Interrogatories
Code of Civil Procedure § 2030.290 governs the procedure for whe...
Nature of Proceedings: Motion Compel Served Verified Written Response/Req. SanctionsMotion to Compel Plaintiff to(1) Serve Verified Written Response to Demand for Production of Documents, and(2) Produce Additional Documents; andRequest for SanctionsRULINGThe Court will GRANT the motion to compel plaintiff to serve a verified response to demand for production, without objection, and produce on or b...
..losed escrow on the home after receiving written notice of a pending dispute between plaintiffs and the sellers. Plaintiffs previously obtained a judgment against the sellers, which has been satisfied. Plaintiffs, ho...
With respect to the below scheduled tentative ruling, no notice of intent to appear is required. If you wish to submit on the tentative decision, you may submit a telefax to Judge DeNoce's secretary, Hellmi McIntyre at 805-662-6712, stating that you submit on the tentative. Do not call in lieu of sending a telefax, nor should you call to see if your telefax has been received. If you submit on the...
..all parties and a proof of service filed with the court. A "notice of ruling" in lieu of this procedure is not authorized.
_____________________________________________
The court's tentative ruling is as follows:
Deny Defendant Linda Corwin's request for an order compelling Plaintiff Julie Walfield's further responses to requests for production (set no. 1), on the ground that Defendant's moti...
CERRITOS FITNESS & HEALTH, LLC v. MLG DEVELOPMENTCASE NO.: VC066078HEARING: 08/16/18#4TENTATIVE RULINGI. Defendants/Cross-Complainants’ MLG DEVELOPMENT and MATTHEW LOUIS GRILL’s motion to compel Plaintiff/Cross-Defendant CERRITOS FITNESS & HEALTH’s further responses to Special Interrogatories (set one) is GRANTED.II. Defendants/Cross-Complainants’ MLG DEVELOPMENT and MATTHEW LOUIS GRILL’s motion t...
..T and MATTHEW LOUIS GRILL’s motion to compel Cross-Defendant CURTIS HARMAN’s further responses to Request for Production of Documents (set one) is DENIED without prejudice....
Currently before the Court are the following matters: (1) the motion by defendant KB Home South Bay, Inc. (“KB Home”) to compel plaintiff Zenith Insurance Company (“Zenith”) to produce a statement of damages and for an award of monetary sanctions; (2) the motion by KB Home to compel Zenith to produce documents responsive to requests for production of documents, set one (“RPD”), and for an award of...
..arrera [(‘Barrera’)] was injured by one or more dangerous conditions (including but not limited to open trenches and construction debris)” while he was lawfully on premises owned, maintained, managed, and operated by Defendants. (Complaint, ¶¶ Prem.L-1 & Prem.L-2.) Plaintiff, the workers’ c...
Robert VArie, Plaintiff, v. Bronislava Zaks, et al., Defendants.Case No.: BC630234Hearing Date: June 26, 2018[TENTATIVE] order RE:Plaintiff’S motion for order compelling Defendant’s Production of Documents Listed in DEPOSITION NoticeBACKGROUNDPlaintiff Robert Varie (“Plaintiff”) moves to compel the production of documents listed in the deposition notice served on defendant Bronislava Zaks (“Defend...
..order compelling the deponent’s attendance and testimony, and the production for inspection of any document. (CCP §2025.450(a).)If a motion seeks to o...
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LAW OFFICES OF OTTO L. HASELHOFF, P.C.
Otto L. Haselhoff, Esq. (SBN 190146)
201 Wilshire Boulevard, Second Floor
Santa Monica, California 90401
Telephone: (800) 667-1880
Facsimile: (800) 667-0991
Email: [email protected]
Website: www. olhpc.com
Attorney(s) for Plaintiff(s)
RYAN LIMA, JR.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF STANISLAUS
RYAN LIMA, JR, an individual;
Plaintiff(s),
vs.
J, JESUS MUNOZ
SUPERIOR COURT OF CALIFORNIA, COUNTY OF PLACER
Date: October 16, 2020 Time: 8:30 AM
Judge: Michael W. Jones Dept.: LM
Reporter: Clerk:
Trofholz Technologies, Inc.vs. Glen, Troy etal [] Presen
10/02/2020
BOUTIN JONES INC.
Robert D. Swanson (SBN 162816)
Ian K. McGlone (SBN 315201)
Suite 1500
Sacramento, CA 95814-4603
Telephone: (916) 321-4444
Facsimile: (916) 441-7597
10/02/2020
BOUTIN JONES INC.
Robert D. Swanson (SBN 162816)
Ian K. McGlone (SBN 315201)
Suite 1500
Sacramento, CA 95814-4603
Telephone: (916) 321-4444
Facsimile: (916) 441-7597
Co Oe IN DH BW NY |
= 6
MARK W. HOSTETTER (CA Bar No. 223264)
LAW OFFICE OF MARK W. HOSTETTER
181 Devine Street
San Jose, CA 95110
Telephone: (408) 375-8545
[email protected]
Attorney for Plaintiff
KEITH ROIZMAN
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
KEITH ROIZMAN, ‘ase No. CGC-19-573153
Plaintiff, URTHER DECLARATION OF MARK W.
OSTETTER IN SUPPORT OF
LAINTIFF'S MOTION TO COMPEL
ACREGEN, INC. TO PROVIDE
'URTHER RESPONSES AN
MARK W. HOSTETTER (CA Bar No. 223264)
LAW OFFICE OF MARK W. HOSTETTER
181 Devine Street
San Jose, CA 95110
Telephone: (408) 375-8545
[email protected]
Attorney for Plaintiff
KEITH ROIZMAN
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
MARK W. HOSTETTER (CA Bar No. 223264)
LAW OFFICE OF MARK W. HOSTETTER
181 Devine Street
San Jose, CA 95110
Telephone: (408) 375-8545
[email protected]
Attorney for Plaintiff
KEITH ROIZMAN
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
JORDAN W. MAURER, ESQ. (Bar No. 303000)
=
FRANK LAW GROUP, P.C.
1517 Lincoln Way, Courthouse Plaza FILED
YH
Auburn, CA 95603 Superior Court of California
SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF PLACER
Physical Address: Mailing Address:
10820 Justice Center Drive PO Box 619072
Roseville, CA 95678 Roseville, CA 95661
08/07/2020
Richard Beckman
2298 Durant Ave
Berkeley CA 94704
Re: Speedboat JV Partners, LLC vs. Capital One, N.A. S-CV-0041499
DOCUMENT:
O Complaint/Petition/Cross-Complaint/Amended CO Answer/Responsive
O Default ONotice of Deposit of Jury Fees
O Motion/OSC/Demurrer O Proof of Service
O Judgmen
Benjeman Beck (SBN: 268617)
CONSUMER LAW EXPERTS, PC
Attorneys for Plaintiffs,
LUCIA GUADALUPE FOX-SOTELO
LUCIA GUADALUPE FOX
ISSAN NORTH AMERICA, INC.; and
Declaration of Nancy Zhang; [Proposed]
Gene V. Halavanau (SBN 267280)
LAW OFFICES OF GENE HALAVANAU
150 Post Street Suite 600
San Francisco, CA 94108
Tel. (415) 692-5301
Fax (415) 692-8412
[email protected]
Aleksandr A. Volkov (SBN 277850)
VOLKOV LAW OFFICE
1200 Mount Diablo Boulevard, Suite No. 205
Walnut Creek, California 945
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF YOLO
CIVIL LAW AND MOTION MINUTE ORDER
HON: DANIEL MWOLK DATE: 07/23/2020 CASE NO.: CVCV-16-663
TITLE: MONSTER LEAD GROUP, INC. VS. CAPITAL PRESORT, INC
ee. REPORTER:
PROCEEDINGS: MOTION". compel Aesperne>
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APPEARANCES
1OPlaintiff Present
Os/t
20WIByAttys:
301Defendant Pres:
Ost
CLERK:-th Cuvery
WARRANT ORDERS
1 O Debtor failed to appear; Warrant of Body
Attachment ordered; Bail set $.
2 U Stay issuance of warrant
