Motion to Compel Further Responses to Special Interrogatories
Moving Party: Defendant Christian F. Paul Responding Party: Plaintiff Nagi Iskander
Ruling: Defendant’s motion to compel further responses to special interrogatories is denied as to Special Interrogatory Nos. 7-16 and granted as to Special Interrogatory Nos. 20-21.
Special Interrogatory Nos. 7-16 call for Plaintiff to precisely state all testimony Plaintiff expects certain witnesses to give at trial. The subject interrogatories request information that is protected by the work product doctrine. The “expected testimony of a witness involves attorney impressions, conclusions, and opinions.” (Snyder v. Superior Court (2007) 157 Cal.App.4th 1530, 1536; City of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 80, abrogated on other grounds.) The motion to compel is denied as to Special Interrogatory Nos. 7-16.
Special Interrogatory Nos. 20 and 21 requests that Plaintiff identify the total financial benefit he received when h