1. Moving Party Defendant New Port Beach Mixed Development, LLC Motion to Compel Further Responses to Requests for Production of Documents, Set Two Against Plaintiff Gerald Conrad
Meet and confer: NPBMD made sufficient efforts to meet and confer on the discovery issues before filing this motion. There were email exchanges, a telephone discussion, and letters regarding the discovery issues. After plaintiffs’ counsel’s 10/1/20 letter stating they would stand on the objections, NPBMD brought the motion.
Merits: RFP No. 59 seeks documents responsive to plaintiffs’ responses to NPBMD’s Special Rogs, Set Two. Plaintiff objected but stated he “has produced or will produce all non-privileged documents.”
RFP Nos. 63, 64, 71, and 72 seek documents relating to payments made by Conrad or affiliated entities to Mills and his entity, Mills real Estate Consulting, LLC. Plaintiff objected but again stated he would “produce all responsive, non-privileged documents.”
RFP Nos. 74-77, 82, 83, and 94-99 se
Hearing Date
November 01, 2020
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1. Moving Party Defendant New Port Beach Mixed Development, LLC Motion to Compel Further Responses to Requests for Production of Documents, Set Two Against Plaintiff Gerald Conrad
Meet and confer: NPBMD made sufficient efforts to meet and confer on the discovery issues before filing this motion. There were email exchanges, a telephone discussion, and letters regarding the discovery issues. After plaintiffs’ counsel’s 10/1/20 letter stating they would stand on the objections, NPBMD brought the motion.
Merits: RFP No. 59 seeks documents responsive to plaintiffs’ responses to NPBMD’s Special Rogs, Set Two. Plaintiff objected but stated he “has produced or will produce all non-privileged documents.”
RFP Nos. 63, 64, 71, and 72 seek documents relating to payments made by Conrad or affiliated entities to Mills and his entity, Mills real Estate Consulting, LLC. Plaintiff objected but again stated he would “produce all responsive, non-privileged documents.”
RFP Nos. 74-77, 82, 83, and 94-99 se