Requests for Production: Defendant has established good cause for its requests. Plaintiff to provide further response to RFP's 1-6, and 9-48 that complies with CCP 3031.240. Plaintiff to amend her responses to RFP 49 in light of any further responses she provides to form and special interrogatories. These RFP's ask for documents in support of the allegations of the complaint, documents relating to the accident, the claim submitted by Chappell, the underlying action, etc. All can be related to the subject and issues of the lawsuit. The Quirk memo to the Consumers Attorneys is simply inapplicable.
Form Interrogatories: Grant in part. Plaintiff to provide further responses to form interrogatory 17.1 as it relates to RFA 6-32. Plaintiff to provide further response to form interrogatory 50.2. Deny motion to compel further responses to form interrogatory 17.1 as it relates to RFA 1-3. The atty-client privilege protects disclosure of communications, not the underlying facts upon which a discl
Hearing Date
January 06, 2021
Category
Civil - Unlimited
Type
Breach of Contract/Warranty
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Requests for Production: Defendant has established good cause for its requests. Plaintiff to provide further response to RFP's 1-6, and 9-48 that complies with CCP 3031.240. Plaintiff to amend her responses to RFP 49 in light of any further responses she provides to form and special interrogatories. These RFP's ask for documents in support of the allegations of the complaint, documents relating to the accident, the claim submitted by Chappell, the underlying action, etc. All can be related to the subject and issues of the lawsuit. The Quirk memo to the Consumers Attorneys is simply inapplicable.
Form Interrogatories: Grant in part. Plaintiff to provide further responses to form interrogatory 17.1 as it relates to RFA 6-32. Plaintiff to provide further response to form interrogatory 50.2. Deny motion to compel further responses to form interrogatory 17.1 as it relates to RFA 1-3. The atty-client privilege protects disclosure of communications, not the underlying facts upon which a discl