BLAIR v. COUNTY OF EL DORADO

(1) Defendant’s Motion to Compel Further Responses to Requests for Production. (2) Defendant’s Motion to Compel Further Responses to Requests for Admission. (3) Defendant’s Motion to Compel Further Responses to Form Interrogatories – General.
(4) Defendant’s Motion to Compel Further Responses to Form Interrogatories. Defendant’s Motion to Compel Further Responses to Requests for Production. The proof of service attached to defense Exhibit 1 declares that on February 13, 2019 requests for production, set one were served on plaintiff’s counsel. Defense counsel declares: on October 2, 2019 defendant mailed a meet and confer letter to plaintiff’s counsel advising him of the overdue discovery, which waived all objections, and requested the discovery be provided by October 11, 2019, otherwise a motion to compel would be filed; on October 8, 2019 plaintiff’s counsel responded that it was reasonable for plaintiff to await the conclusion of the demurrer process before answering any........