(1) Motion by Intervenor-Plaintiff U.S. REAL ESTATE CREDIT HOLDINGS III, L.P. to Compel Amended Responses to, and Production of Documents in Connection with Requests for Production of Documents, Set One, and Requests for Sanctions;
(2) Defendant BMO HARRIS BANK, N.A.’s Motion for Relief From Waiver of Objections to Requests for Production of Documents, or in the Alternative, for a Protective Order
TENTATIVE RULING
Upon the service of a set of requests for production of documents, the party targeted by those requests has 30 days to serve responses, and to produce responsive documents. C.C.P. §2031.260. However, that deadline can be extended by the propounding party, as long as the agreement to extend is “confirmed in a writing that specifies the extended date . . . .” C.C.P. §2031.270(a),(b).
USRECH here extended in a writing BMO’s deadline for responses to August 19. Then, on August 16, BMO requested another extension. While USRECH’s counsel agreed via email to allow production of resp