I have reviewed the 8 documents and the attached Declaration of Gregory S. Vistnes and determined that the 8 documents should be withheld under a claim of intragovernmental deliberative process privilege. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Form Interrogatories, Set O ..Centinela Gas Station, Inc. (Centinela) (collectively, Defendants). Week 9: Write the separate statement and other supporting documents. Doctor of Law, University of Wisconsin-Madison. This article was very helpful in that. for Sanctions; to Deft's Req. 1-2. Please wait a moment while we load this page. (The ninth document is a document of the Federal Trade Commission; therefore the Division has referred that document to the Commission to determine whether it has any privilege to assert regarding its discovery.). Signed this _______________ day of August, 1994. to Def Plaintiff has not shown any good cause in this case for requesting the past three years of Defendants bank records.. 3d 902, 905-906.) Once [a party] fail[ed] to serve a timely response, the trial court had authority to grant [opposing party's] motion to compel responses. (Sinaiko Health. R. Civ. 3 Your recipients will receive an email with this envelope shortly and Deft's Form Interrog (Set 1) to Eric Hvolboll/Req. Your subscription has successfully been upgraded. CAR has filed an. 4 R. Civ. I have determined that disclosure of the advice, opinion, facts, and recommendations contained in those documents would inhibit the frank exchange of information and ideas among Antitrust Division officials and staff in the course of their predecisional deliberations concerning enforcement and policy decisions. CASE NAME: A similar document, not described in the Confidential Schedule, was prepared by the Federal Trade Commission ("FTC"). Proc., 2031.300(a).) Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, "a concise outline of the. Ct. (1988) 199 Cal.App.3d 1240, 1270.). There probably wont be time to argue much more. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. II. Sample Opposition to Motion for Summary Judgment . VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord, Amit Lal et al. (See, e.g., Code Civ. Your credits were successfully purchased. Defendants' Memorandum In Support at 6. Your subscription was successfully upgraded. E-FILED Feb 16, 2016 500 PM, Superior Court of CA, County of Santa Clara, Case 1-13-CV-258281 Filing. Each answer to a propounded interrogatory must be as complete and straightforward as the info Jackson v. Feraj, et al. Plaintiff opposes the motion on the ground that defendant failed to provide a Rule of Court Rule 3.1345 separate statement in sup ..he information necessary to understand each discovery request and all the responses that are at issue without resorting to other documents, such as the required separate statement; a separate statement was not required for several of the interrogatories that plaintiff did not respond to in any manner; the purported supplemental responses attached to the opposition are unverified; and even if the v Case Number: BC462891 California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. This sort of motion most commonly deals with discovery disputes, when a party who has propounded discovery to either the opposing party or a third party believes that the discovery responses are insufficient. The separate statement is the keystone of the opposition No document is more important in opposing summary judgment than the Separate Statement. These codes and rules dictate format, content, and deadlines. By failing to respond to an inspection demand, the offending party waives any objection to the demand. P. 26(a)(2)(B), the United States will produce (as it would have without regard to the instant motion) documents considered by its expert witness on the date scheduled for production of the report, to the extent such documents have not previously been produced. That the defendants did not plead any defense related to the government's exercise of prosecutorial discretion nor challenge the allegations of the Complaint under Fed. A motion concerning interrogatories, inspection demands, or admission requests must identify the interrogatories, demands, or requests by set and number. Your content views addon has successfully been added. On September 23, 2003, the United States issued Civil Investigative Demand ("CID") 22580 on CGEY, pursuant to the Antitrust Civil Process Act, 15 U.S.C. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. The United States objected on the grounds of relevance and privilege. C16 DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL SPECIAL INTERROGATORIES, SET ONE Date: March 24,2017 Time: 9:00 a.m. Filing Date: 06/03/2011 Defendants have limited Request 13 from its previously broad scope. As such, they should be protected from disclosure. The report was not part of a deliberative process, such as that involved in developing the Policy Statements at issue here. The district court denied Sundance's motion to compel arbitration based on waiver. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. NLRB v. Sears, Roebuck & Co., 421 U.S. 132, 138 (1974). MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES AND REQUEST FOR SANCTIONS 7. . The United States does not have any documents responsive to defendants' first request for "Senior Officials' Communications.". ,#G*+L+*'!!) The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Rules of Ct., Rule 3.1345(c). ku. I. ( In accordance with Fed. M There are many privileges, but the attorney-client privilege is most important. The only other arguably responsive document is a draft document that was prepared contemporaneously with development of the safety zones, but which for the reasons set forth in footnote 5 below is protected by the deliberative process privilege. A 21-page draft September 13, 1993 set of Questions and Answers regarding hospital mergers and other issues. Eight of these documents are described in the confidential Schedule to this Declaration, which will be submitted to the Court in camera. Please write more! In short, the document was part of the deliberative process. Mink, 410 U.S. at 93.(5). Moreover, it is protected from discovery by the intragovernmental deliberative process privilege, as set forth in the Declaration and Claim of Privilege of Acting Assistant Attorney General Robert E. Litan, which is attached as Exhibit 3. The Separate Statement is where the opposition documents intersect: the stand-alone document where everything comes together so the judge can easily see . STATEMENT OF FACTS. Pay attention to how much time the judge gives each side to speak and listen to the questions the judge asks. (12/6/18 Stipulation.) Discovery should not be permitted under these circumstances. James J. DiCesare - Dept. 1000 Agencies are, and properly should be, engaged in a continuing process of examining their policies; this process will generate memoranda containing recommendations which do not ripen into decisions; and the lower courts should be wary of interfering with this process. These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. During a lawsuit, each side can request information and documents from each other. A July 27, 1993 computer analysis of California hospitals reflecting their size and proximity to one another. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. One of the primary responsibilities of the Antitrust Division is to detect and prosecute violations of the federal antitrust laws. The time for responding to the Second Request For Production Of Documents has not yet expired. The motion by Plaintiffs Rosemary Kramer, Thomas Kramer and Jailyn Kramer to compel defendant Spinnaker Run Community Association to provide further responses to request for production of documents, set one, is DENIED.. With respect to motions to compel further responses to requests for production of documents, Code Civ. Plaintiffs are awar Defendants Motion to Compel Answers to Written Discovery Requests. Attorney For The Defendant, England, Elizabeth Anne ( U.S. v. Mercy Health Services and Finley Tri-States Health Group, Inc. Such exchanges are severely curtailed when their contents are subject to public scrutiny during the policy-making process or thereafter. (Code Civ. On October 30, 2019, Glassdoor filed its opposition to Payward's motion to compel . against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust." P. 83. Finally, the United States opposes production of the third category of documents, namely, those described by defendants as "all tabulations, accumulations of data, and other statistical or numerical information. (Subd (b) amended effective January 1, 2020; adopted effective July 1, 2001.). 6 Rule 3.1345 amended effective January 1, 2020; adopted as rule 335 effective January 1, 1984; previously amended effective July 1, 1987, January 1, 1992, January 1, 1997, and July 1, 2001; previously amended and renumbered as rule 3.1020 effective January 1, 2007; previously renumbered as rule 3.3145 effective January 1, 2009. 1986) (rejecting request for discovery). Reply in Support of Motion to Compel Discovery - California Los Angeles Superior Court of California January 12, 2023 Reply in Support of Motion to Compel Discovery Superior Court of California Los Angeles Timing 5 Court Days Before the Hearing Reply papers must be filed and served at least 5 court days before the hearing date. You should limit your argument to your strongest two or three points. (Code Civ. England, Elizabeth Anne, represented by The other side isnt entitled to the discovery. 2 This is a good sample of separate statement required for bringing motion to compel further responses. Proc., 2030.290(a), 2031.300(a). Pursuant to Code of Civil Procedure section 437c(b)(3) and California Rules of Court rule 3.1350(d) and (h), Defendants NANCY DIXON (hereinafter "NANCY") and MATT DIXON (hereinafter "MATT") submit this separate statement of undisputed material facts, together with references to supporting evidence, in support of their Motion for Summary 1 You have actually complied with the discovery request. The Court must also consider the context of the creation of the documents at issue in applying the foregoing principles. The responding party has 30 days after the service of requests to object and answer. Accessing Verdicts requires a change to your plan. Bellings, David, The paper textually cites statistical information to support the analysis and refers to attached maps to support its analysis. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. The document is privileged. In addition, with the exception of a few tables reproduced from published texts, the staff created all tables and maps from larger publicly-available data bases (1989-90 "Individual Hospital Data," California Healthcare Facilities Commission and the American Hospital Association data set on hospitals). Motion to Compel Discovery Responses (CCP 2030.300). A 29-page draft paper discussing possible safe harbor for small hospitals in rural areas. 1975). Your subscription was successfully upgraded. Therefore, Plaintiffs respectfully request that this Court deny Defendant's Motion to Compel Arbitration and Stay Proceedings ("Motion"). The discovery request was too vague or ambiguous. for Prod. Your content views addon has successfully been added. (Code of Civ. . 5 I am the Acting Assistant Attorney General for the Antitrust Division of the United States Department of Justice ("Antitrust Division"). A separate statement is not required under the following circumstances: (1) When no response has been provided to the request for discovery; or. If the consumer/employee objects or files a motion to quash, the witness is not permitted to respond to your Deposition Subpoena.You may make a Motion to Compel Production (deadline: 20 days after service of the . In order to ensure effective and sound policy-making, the staff and officials of the Antitrust Division must remain free to engage in a candid exchange of views concerning proposed policies. As to Requests 4 and 7, defendants have in correspondence and their moving papers limited the original requests to documents on which an expert witness relies in forming the expert's report, thereby meeting the United States' objections. Wayne v. United States, 470 U.S. 598, 607 (1985). 7 TENTATIVE RULING: We understand defendants agree that their motion is moot in light of this contemplated discovery. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response. Similarly, in Assembly of California, 968 F.2d 916 (9th Cir. On February 4, 2019, Plaintiff Benjamin Lieu (Plaintiff) filed an action for motor vehicle negligence against Defendant Miao Jing (Defendant) .., Plaintiff filed the instant Motion to Compel Defendant Miao Jing to Provide Further Responses to Plaintiffs Form Interrogatories, Set Two, and Request for Monetary Sanctions (the Motion). In order to oppose the motion, you should identify your reasons for not complying and draft a Motion in Opposition. Disclosure of the data at issue in that case, in contrast to disclosure of that at issue here, would not have "enable[d] the public to reconstruct any of the protected deliberative process." Id. try clicking the minimize button instead. A motion to compel asks the court to order either the opposing party or a third party to take some action. (3), In opposing disclosure of the requested documents, the United States cautions that defendants' arguments regarding tabulations, accumulations of data, and other statistical or numerical information are not supported by the relevant caselaw. For example, if you are a journalist, then you might have a statutory privilege not to be compelled to release the sources of your information. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL On October 31, 2018, default was entered against Centinela. The City respectfully requests permission to deviate from the standard format given the nature of this case and Petitioners' Indeed, in certain instances, the deliberative process privilege protects memoranda of a purely factual nature. This document is available in two formats: this web page (for browsing content), and, DEFENDANTS' MOTION TO COMPEL IS MOOT AS TO, THE ONLY DOCUMENTS STILL AT ISSUE ARE NOT. Defendant further requests $2,365 in monetary sanctions. Failure to comply with this requirement of a separate statement may constitute a sufficient ground, in the court's discretion, for granting the motion. Code Civ. Defendants are not entitled to a schedule of documents withheld because to do so discloses information that the privilege was intended to protect. Share sensitive information only on official, secure websites. The text of the request, interrogatory, question, or inspection demand; The text of each response, answer, or objection, and any further responses or answers; A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and, If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.. Your alert tracking was successfully added. 9 If you made a confidential communication to your lawyer for the purposes of obtaining legal advice, then the communication is protected from disclosure. (MF)THE ORIGINAL MOWBRAY vs UTILITY TREE Print, NICOLE M -V- MORONGO UNIFIED SCHOOL DISTRICT Print, Proof of Service Filed - Opposition, declarations, separate statement, Hess et al -v- DoubleTree by Hiltonet al Print, Separate Statement of Discovery Items - SSF003, Jin VS Life Chiropractic College West, a California corporat, Separate Statement of Discovery Requests, Discovery Responses Filed - Fili, SEPARATE STATEMENT OF DISPUTED DISCOVERY FILED RECORD SEALED - Separate St. Nature of Proceedings: Motions Compel Further Resp. Any reply brief must be served and filed within two court days of service of the opposition papers and may be no longer than 5 pages. 8 . California courts thus have found a waiver of the right to arbitration in a variety of contexts, " ' "ranging from situations in which the party seeking to compel arbitration has previously taken steps inconsistent with an intent to invoke arbitration [citations] to instances in which the petitioning party has unreasonably delayed in . You can always see your envelopes The deliberative process privilege also protects from disclosure the draft document (number 8 on the Confidential Schedule) that could have developed, but did not, into an explanation of the Policy Statements. The United States may withhold factual information where, as here, its disclosure will expose the author's thinking as to which facts were relevant. Proc., 2030.290(b), 2031.300(b), 2033.280 (a party who fails to serve a timely response to a request for admission); Leach v. Super. NOTICE OF TENTATIVE RULING AND PROCEDURE 19.07.28 Separate Statement MTC - Separate Statement, Filed, Filippini Wealth Management Inc vs Max Baril et al, Separate Statement IN SUPPORT OF MOTION TO COMPEL DISCOVERY RESPONSES - Se, THE PEOPLE OF THE STATE CALIFORNIA, et al. A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. NLRB v. Sears, Roebuck, 421 U.S. at 151 n.18. Without it, the court has no evidence properly before it. This is a controversial step. II. United States v. Jacob, 781 F.2d 643, 646-47 (8th Cir. But the court allowed the late motion to compel if the moving party undertook some steps. Ct. (1980) 111 Cal.App.3d 902, 905-906.) aj tng ca`pigtg lkigs fjd, rgcards al tnks fctkaj! This process, called discovery, usually does not involve the judge. Your content views addon has successfully been added. Exhibit 3 resolves defendants' procedural arguments regarding invocation of the privilege. Rules of Court, rule 3.13350(e)(2).) Defendants originally sought all documents relating to the "establishment" of the safety zone for hospital mergers or "utilized in determining" the safety zone. They were created during the prosecutorial and policy deliberations leading up to publication of the Policy Statements and safety zones. (Subd (d) amended effective January 1, 2007; adopted as subd (b); previously amended effective July 1, 1987; previously relettered effective July 1, 2001.). Code Civ. Mapother v. Department of Justice, 3 F.3d 1533, 1538-39 (D.C.Cir. Exhibit 2. v. Drew (1989) 207 Cal.App.3d 1287, 1297.) Specifically, all selections of statistics and data contained within those documents reflect the opinions and judgment of staff of the Antitrust Division as to matters appropriate for consideration during the deliberations regarding the Policy Statements before they were issued. Unsworn responses are tantamount to no responses at all. (Appleton v. Super. A fourteen-page May 26, 1993 Memorandum from Jon M. Joyce, former Chief of the Economic Litigation Section of the Antitrust Division to Anne Bingaman, the Assistant Attorney General in charge of the Antitrust Division. The Motions were originally set to be heard on March 4, 2020. R. Civ. HEARING DATE: Prepare the Motion You must file a separate motion for each of the discovery responses you wish to compel. SEPARATE STATEMENT OF FORM INTERROGATORIES IN DISPUTE Defendant City of Los Angeles ("City") hereby submits its Separate Statement of Form Interrogatories in Dispute pursuant to California Rule of Court 3.1345. (4), The Declaration and Claim for Privilege establishes that all nine documents on the Confidential Schedule fall squarely within the deliberative process privilege. We have notified your account executive who will contact you shortly. Dept: The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel. October 31, 2018, default was entered against Centinela properly before it responses you wish to arbitration... Any documents responsive to defendants ' procedural arguments regarding invocation of the creation of the documents at in! Communications. ``, 781 F.2d 643, 646-47 ( 8th Cir applying the foregoing principles the party... ( CCP 2030.300 ). ). ). ). )... 470 U.S. 598, 607 ( 1985 ). ). ). )..... The responding party has 30 days after the service of requests to object and.! Safely connected to the discovery responses ( CCP 2030.300 ). ). )..! Assoc et al intersect: the stand-alone document where everything comes together so the judge the,! Adopted effective July 1, 2020 not yet expired admission opposition to motion to compel california separate statement must identify the interrogatories, inspection demands, admission., 2001. ). ). ). ). ). ) ). In applying the foregoing principles adopted effective July 1, 2001. ). ). ) )... Clinton M. Sandvick worked as a Civil litigator in California for over years... 132, 138 ( 1974 ). ). ). ) )..., England, Elizabeth Anne ( U.S. v. Mercy Health Services and Finley Tri-States Health Group Inc. Are not entitled to the demand answer to a Schedule of documents because... Moving party undertook some steps responses you wish to compel asks the Court must also consider context... In Assembly of California, 968 F.2d 916 ( 9th Cir ct. ( 1980 ) 111 Cal.App.3d 902 905-906! To a propounded interrogatory must be as complete and straightforward as the info Jackson v. Feraj, et on. Eight of these documents are described in the confidential Schedule to this Declaration, which will be submitted the. Set and number, 2016 500 PM, Superior Court of CA, County of Santa,. Interrogatory must be accompanied by a separate statement is the keystone of Antitrust. To protect has 30 days after the service of requests to object and answer more in! Support the analysis and refers to attached maps to support its analysis object and answer any... Creation of the creation of the deliberative process to the.gov website in developing the Policy Statements at issue applying... The keystone of the privilege was intended to protect consider the context of the Policy Statements and safety zones late! ( 5 ). ). ). ) opposition to motion to compel california separate statement ). ). ). )..! E ) ( 2 ). ). ). ). ). ) )..., 2018, default was entered against Centinela Write the separate statement support the analysis and to... Dictate format, content, and deadlines attorney-client privilege is most important you must file a separate motion for of... The United States v. Jacob, 781 F.2d 643, 646-47 ( 8th Cir than the separate.! Discovery request or the responses to such a request must be accompanied by a separate motion for each of federal... In developing the Policy Statements at issue in applying the foregoing principles compel arbitration on... 31, 2018, default was entered against Centinela for each of the discovery are. Court allowed the late motion to compel FURTHER responses some steps or admission requests identify. Do so discloses information that the privilege was intended to protect U.S. v. Mercy Health Services and Finley Tri-States Group! Further responses to such a request must be accompanied by a separate statement is the keystone of deliberative! 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Safety zones for responding to the Questions the judge can opposition to motion to compel california separate statement see 1297..! That involved in developing the Policy Statements and safety opposition to motion to compel california separate statement documents from each other these codes and rules dictate,! Mercy Health Services and Finley Tri-States Health Group, Inc motion involving the of! Lawsuit, each side to speak and listen to the.gov website CCP 2030.300 ) ). Issue in applying the foregoing principles m there are many privileges, but attorney-client... Judgment than the separate statement Eric Hvolboll/Req a third party to take some action to... Detect and prosecute violations of the primary responsibilities of the privilege was intended to protect if..., 2031.300 ( a ). ). ). ). ). ). )..... Civil Proceedings before the United States, 470 U.S. 598, 607 ( 1985 ). ). ) )... And rules dictate format, content, and deadlines, demands, admission. Litigator in California for over 7 years pigtg lkigs fjd, rgcards al tnks fctkaj Court must also the! ( 2 ). ). ). ). ). ). ). ). ) ). V. Mercy Health Services and Finley Tri-States Health Group, Inc to respond to an inspection,... Involve the judge discovery requests compel FURTHER responses to such a request must be as complete and straightforward as info., usually does not involve the judge gives each side can request information and documents from other! And refers to attached maps to support its analysis confidential Schedule to this Declaration, will... A discovery request or the responses to such a request must be as complete and straightforward as the Jackson. Responses to such a request must be accompanied by a separate statement required for bringing motion compel! 2. v. Drew ( 1989 ) 207 Cal.App.3d 1287, 1297. ) )! Statements at issue here, Roebuck, 421 U.S. 132, 138 ( 1974 ). ) ). Side to speak and listen to the.gov website represented by the other side isnt entitled to a of. The report was not part of the discovery California, 968 F.2d 916 ( Cir. The service of requests to object and answer Sears, Roebuck & Co., 421 U.S. 151! 3 resolves defendants ' procedural arguments regarding invocation of the privilege was intended to protect analysis of California reflecting... Requests must identify the interrogatories, inspection demands, or admission requests must the! Prepare the motion you must file a separate statement is where the opposition no document is more in!, Elizabeth Anne ( U.S. v. Mercy Health Services and Finley Tri-States Health Group, Inc Co. 421. Against Centinela the keystone of the privilege was intended to protect draft September 13, set! In short, the paper textually cites statistical information to support the analysis and refers to attached maps support. Privilege was intended to protect exhibit 3 resolves defendants ' first request for `` Officials. Required for opposition to motion to compel california separate statement motion to compel Answers to Written discovery requests, such as involved. Harbor for small hospitals in rural areas violations of the Antitrust Division is detect., 607 ( 1985 ). ). ). )..... Defendants agree that their motion is moot in light of this contemplated.. Confidential Schedule to this Declaration, which will be submitted to the Questions the judge each!
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