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informal discovery request californiainformal discovery request california

within 10 calendar days after the initial request, the request shall be deemed denied. If you need informationfrom your spouse, domestic partner, or someone else, you can use a legal process (called discovery) to get this information. Your credits were successfully purchased. Written Discovery: Interrogatories and Requests for Admission Interrogatories are questions requiring your version of the facts and of your claims. SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES . xb```") |@Qw"A9R ! Is your law firm cloud adoption happening as quickly as it should? 0000002081 00000 n There is some truth to this because it is the application of the law to the facts that determines outcomes. It is not generally governed by any rules, scheduling orders, or officially approved techniques. ,[%_\cEDt_!UV"hhM F- ), The Legislature passed AB 383, which adds 2016.080 to the Code of Civil Procedure, effective January 1, 2018. There are several reasons. We have extensive experience helping our clients select the right tools during divorce to properly move forward with their case. (e)The outcome of an informal discovery conference does not bar a party from filing a discovery motion or prejudice the disposition of a discovery motion. All rights reserved. They were placed on your computer when you launched this website. (a) If an informal resolution is not reached by the parties, as described in Section 2016.040, the court may conduct an informal discovery conference upon request by a party or Beyond these client-directed sources, think in terms of finding relevant people, documents and tangible evidence using common sense and any real-world experiences. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SOLANO . You may receive requests for discovery from the other side The client can give you information about where the occurrence in question took place to permit a viewing of the scene. California Code of Civil Procedure section 2025.480, subdivision (a) states: If a deponent fails to answer any question . 0d>j`Ja{6)" \ 4 HmBrU5ybE!\mZVh*]R D)@Zg >b620@zXu2fa`;Ua| w( sometimes almost identical, motions required for each discovery request, and require a filing fee for each such motion. 4 0 obj %PDF-1.4 % h8I >a]M,j.S/;BiaWH*nH7_!gXK;2fbMs3S/8)-"KHZG_]Uu%X6m0Ky> hh"MrEO*z'MR0x$cv 4,&eV(Etii$M ^@XN'H7Ob8%!YAN"9g |I_u,o (pD]YLZ$=tor+(=lXb~+w 405 0 obj <>/Filter/FlateDecode/ID[<5D2D920AAA8D754498483A068A503D49>]/Index[369 81]/Info 368 0 R/Length 124/Prev 623004/Root 370 0 R/Size 450/Type/XRef/W[1 2 1]>>stream Format of discovery motions (a) Separate statement required . If you wish to keep the information in your envelope between pages, Proc., 2016.080(c)(2). Any party may file a response to a declaration filed pursuant to this subdivision. on the court's own motion for the purpose of discussing discovery matters in dispute BACKGROUND You can request it via informal discovery even if you haven't decided whether you want to go to court or not. Your Informal Discovery Request should be sent to The custodian of Records at the CHP office the officer who issued you the citation works out of. Let our 300 expert attorney-editors keep you up to date on ever-changing laws, Sign up for a monthly newsletter designed for legal professionals like you. will be able to access it on trellis. Rule 3.1345. An Informal Discovery Conference, commonly abbreviated as "IDC," is an informal proceeding used by the courts to encourage resolution of disputes, particularly discovery-related disputes, prior to the filing of a motion; a forced further meet and confer, if you will. . California discovery methods include depositions, interrogatories, requests for admissions, requests to produce, medical examinations, and requests for exchange of expert witness information. 2. The City Attorney is in the Torrance Courthouse. ORDER RE: did this information help you with your case? If this happens, you have specific requirements and deadlines for responding. They also must respond. 0 Formal requests may be filed under some circumstances, not letter requests. (a) A member of the public can make a PRA request in writing, over the telephone, or in person. Written requests can include letters, e-mail, and fax. We noticed that you're using an AdBlocker. Access accurate legal research and comprehensive content on Westlaw for as low as $97/month. Only existing records in the Department's possession would be responsive to a PRA request. Parties may file a joint statement that they all sign or they may file individual statements. Case Number: Space below for use of Court Clerk only . Proc., 2025 (o).). In Carter v. Superior Court (1990) 218 CA3d 994 (pdf) the court held even though a party had missed the deadline for compelling inspection of documents under C.C.P. 0000008950 00000 n research, Investigate and mitigate 7 Parties can request an Informal Discovery Conference ("IDC") in unlimited civil cases pursuant to Code of Civil Procedure section 2016.080. 415 0 obj <>/Filter/FlateDecode/ID[<6C700875FFC54C4F86C7748D1BA8C532>]/Index[403 35]/Info 402 0 R/Length 69/Prev 45460/Root 404 0 R/Size 438/Type/XRef/W[1 2 1]>>stream & The way to complete the Informal discovery request on the internet: To start the blank, utilize the Fill camp; Sign Online button or tick the preview image of the document. But, to prepare for trial, you will use the formal discovery process. Deadline for Court to decide on Request: _____ (insert date 10 . Last. Accessing Verdicts requires a change to your plan. endobj ), If an informal discovery conference is granted or ordered, the court may toll the deadline for filing a discovery motion. (Code of Civ. (a) If an informal resolution is not reached by the parties, as described in Section 2016.040, the court may conduct an informal discovery conference upon request by a party or on the court's own motion for the purpose of discussing discovery matters in dispute between the parties. (b) If a PRA request is made, an employee of the Department shall And, of course, there are also "Requests for Production of Documents and Things" that can force a party to turn over actual documents and things like DVDs . Once you have done that you can move on to supporting areas of strength (corroboration) and trying to find evidence that fills the gaps, or weak areas (substantiation). Rule 3.725 of the California Rules of Court says every party has to file this form at least 15 days before the first Case Management Conference. Case analysis, which we just discussed, is going to be your guide. Alan Eisner Van Nuys, California (818) 781-1570 (818) 788-5033 Email Me Alan Eisner has practiced criminal law for over 28 years in Los Angeles County . If a resolution is not reached, parties are required to have an informal discovery conference (IDC) with the Court before filing any discovery motion, unless otherwise authorized by the Court. The other person must respond to your request and swear how they responded is true In a formal discovery, you formally ask for information and documents. Most of these techniques can be easily adapted to use as we shelter in place. What is an Informal Discovery Conference? All Thomson Reuters websites use cookies to improve your If you are requesting Discovery in a civil case, the Discovery Technician is available Monday - Friday from 7:00am - 5:00pm and can be reached at (707) 543-4033 or via email at srpd-discovery@srcity.org. Proc., 2016.010-2036.050). This sample request for discovery in a California criminal case is served pursuant to Penal Code section 1054.5 (b) and is used by a defendant or their attorney to request all materials and information specified in Penal Code section 1054.1 from the prosecuting attorney who then has 15 days to furnish the requested items. According to this section, [i]f an informal resolution is not reached by the parties, as described in 2016.040, the court may conduct an informal discovery conference upon request by a party or on the court's own motion for the purpose of discussing discovery matters in dispute between the parties. (Code of Civ. In this case, your deadline is the next week day. The Court may order the parties to conduct an informal discovery conference . (g) This section shall remain in effect only until January 1, 2023, and as of that Where significant facts are not essentially disputed, courts typically enter judgment by motion rather than trial. intelligence, 4 reasons why client portal software is a good idea for law firms, How the right legal technology can help you secure wins in court, What litigators can learn from the Odell Beckham Jr. Nike lawsuit, 4 ways legal tech optimizes hybrid workplace environments, How to develop a business-cloud strategy for law firms. (Stewart v. Colonial Western Agency, Inc. (2001) 87 Cal.App.4th 1006, 1012-1013.) (2)If an informal discovery conference is granted or ordered, the court may toll the deadline for filing a discovery motion or make any other appropriate discovery order. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2016-080/. You can always see your envelopes > > Read More . How do you decide what information you might need to develop during informal discovery? California Highway Patrol. Hearing Date: May 10, 2019 Current as of January 01, 2019 | Updated by FindLaw Staff. This note will focus on discovery procedures pursuant to California's Code of Civil Procedure. and reinvest any monies in the debt service account as provided by 5-873. The purpose of the Discovery Facilitator and Evaluator Program is to allow parties and counsel to resolve discovery disputes in a manner that is less expensive, more flexible and participant-controlled than a standard discovery motion, and that avoids the risk of sanctions inherent in formal discovery motion practice. Following a reasonable and good faith attempt at an informal resolution of each issue to be presented, a party may request an Informal Discovery Conference pursuant to the following procedures: a. CASE NUMBER: 1. &:_!Xp?eO"JW!2E#%!bB The person you need information or answersfrom is required to respond to your request. 449 0 obj <>stream California Civil Discovery Practice. Categories C.All monies earned as interest or otherwise derived from the investment of the monies Informal discovery means sharing information voluntarily. FOIA is Federal. ), Personal Injury Non-Motor Vehicle Unlimited, 1 Copyright 2023, Thomson Reuters. endstream endobj 136 0 obj<>/Metadata 12 0 R/PieceInfo<>>>/Pages 11 0 R/PageLayout/OneColumn/StructTreeRoot 14 0 R/Type/Catalog/LastModified(D:20120830152057)/PageLabels 9 0 R>> endobj 137 0 obj<>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageC/ImageI]/ExtGState<>>>/Type/Page>> endobj 138 0 obj<> endobj 139 0 obj<> endobj 140 0 obj[/Indexed 146 0 R 255 147 0 R] endobj 141 0 obj<> endobj 142 0 obj<> endobj 143 0 obj<> endobj 144 0 obj<>stream 0000002807 00000 n 34 o$IxIxhx-)4 rwtex_t).@_(rcU#auX(&Y\i?ZMT \^P'?y,"!,nk CU,ym?Sg#X=@$* l[`L{ j&FE.Ls&dBb|VQP|>G}&s5y?} \:2$%QLZd[)1bd94|+XTxa$Qo"Uq\C -[9glH\$gXW5c\a?pDFUvxd&[ Counsel must have exhausted all meet and confer obligations before the Informal Discovery Conference. FOR MORE INFORMATION . Copyright - California Business Lawyer & Corporate Lawyer, Inc. in the debt service account shall be credited to that account. rule should be read in conjunction with Part I.G. that a party has not complied with Section 1054.1 or 1054.3 and upon a showing that the moving party complied with the informal discovery procedure provided . (2) If an informal discovery conference is granted or ordered, the court may toll When seeking informal discovery, mail a copy of your citation to the issuing law enforcement agency. Description: This sample request for an informal discovery conference in California is authorized by Code of Civil Procedure section 2016.080 and can be used to request that the court conduct an informal discovery conference so that the discovery matters that are in dispute between parties to litigation can be discussed and hopefully resolved. As part of the lawsuit, the other side may send you request for information or evidence. Initiation - Two paths. If a court is in session and does not grant, deny, or schedule the partys request within 10 calendar days after the initial request, the request shall be deemed denied. 0000008061 00000 n 0 To do this, you use a subpoena. Your alert tracking was successfully added. order. Depending on the county you may even have to engage in an informal discovery conference before being allowed to reserve a motion date. schedule and hold the conference no later than 30 calendar days after the court granted %%EOF Penal Code 1054.1 and 1054.5. <> Discovery is how you gather the evidence you will need to prove your case as plaintiff, or defeat the plaintiffs case as a defendant. <> California civil discovery is primarily regulated by the Civil Discovery Act of 1986, CCP 2016\u20132036. This . 403 0 obj <> endobj For example, if your spouse refuses to answer your questions or provide information, you can ask a judge to order your spouse to followthe law and even pay fees. Technology can be particularly useful. 3 0 obj ADR is usually less formal, less expensive, and less time-consuming than a trial. On your citation you will see a box marked "Area." If it contains the numbers 765, send your Informal Discovery Request to: Custodian of Records. Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2016.080 - last updated January 01, 2019 Another way you can get information from the other sideis to have themgive sworn testimony outside of court (before the trial) in a deposition. PLAINTIFFS MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFFS REQUEST FOR PRODUCTION OF DOCUMENTS If you are the plaintiff in a case, you have the burden to prove your case by stronger evidence than the other side. As part of discovery, sometimesyou need tohave an individual (or company) who is not a party to the case produce documents or business records. The forms of discovery to use in a case depends on factors unique to each case. No party may move to compel discovery or file any other discovery motion until the parties have had an Informal Discovery Conference with the court. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2016-080/, Read this complete California Code, Code of Civil Procedure - CCP 2016.080 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. San Mateo LR 3.700 (a) (amended eff 7/1/22). (d) If an informal discovery conference is not held within 30 calendar days from the date the The court can penalize (sanction) someone who does not follow the discovery rules. We will email you A trial judge's perceptions on such matters, inherently factual in nature at least in part, must not be lightly disturbed. It is part community property. Among the factors the court should consider are the history of the litigation, the nature of the interaction between counsel, the nature of the issues, the type and scope of discovery requested, and the prospects for success. help you understand what Requests for Production are, and how to propound these types of requests. 07-28-2015, 04:16 PM #3. betabun. 10 The advanced tools of the editor will direct you through the editable PDF template. the request or issued its order, and before the discovery cutoff date. Adding your team is easy in the "Manage Company Users" tab. The Civil Panel is pleased to offer Informal Discovery Conferences to resolve discovery disputes in cases impacted by our reduced staffing due to the COVID-19 pandemic. It can reveal information more profound than that procured under the rules of civil procedure and yet can be much more cheaply obtained. It would also help to be able to see documents showing what the other party claims about their finances, such as past tax returns, bank . Request for Issuance of Bench Warrant of Arrest and Notice to Sheriff ADM-374 (Rev. STREET ADDRESS: 600 Union Avenue . This proof chart, which may be very rudimentary at the outset of the case, will essentially help the advocate determine where their clients anticipated case has evidentiary strength and weakness. The motion by Plaintiffs Scott Patrick Ludwig and Heather Ludwig (jointly, Plaintiffs) to compel further responses to Plaintif ..y a party or on the court's own motion for the purpose of discussing discovery matters in dispute between the parties. Pursuant to that Section, and the Courts power to amend and control its process and orders so as to make them conform to law and justice pursuant to CCP 128(a)(8), the Court orders the parties in this case to participate in an Informal Discovery Conference (IDC). Your subscription has successfully been upgraded. (a) If an informal resolution is not reached by the parties, as described in Section 2016.040, the court may conduct an informal discovery conference upon request by a party or on the court's own motion for the purpose of discussing discovery matters in dispute between the parties. 3. We'll only use this email to send this link. endobj But, to prepare for trial, you will use the formal discovery process. The divorce discovery process can be an informal exchange of information, or it can follow a rigid procedure. You can get more information about these types of discovery from a lawyer or law library. Read the code on FindLaw . The client may have some idea of the identity of other witnesses or involved parties. If you're involved in an attorney-driven divorce (aka litigation . endstream endobj 404 0 obj <>/Metadata 24 0 R/OCProperties<>/OCGs[417 0 R]>>/Outlines 72 0 R/PageLabels 399 0 R/PageLayout/OneColumn/Pages 401 0 R/Perms/Filter<>/PubSec<>>>/Reference[<>/Type/SigRef>>]/SubFilter/adbe.pkcs7.detached/Type/Sig>>>>/PieceInfo<>>>/StructTreeRoot 85 0 R/Type/Catalog>> endobj 405 0 obj <>/Font<>/ProcSet[/PDF/Text]>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 406 0 obj <>stream Some forms of discovery are relatively easy to do and involve using court forms with standard questions. 08/2022 Page 1 of 1 Optional (Local Rule 3.15) I, , request an informal discovery conference. Stay up-to-date with how the law affects your life. Requests for Proposals . Northern District of California Local Rule 16-1. risk, Fast-track drafting and (c)(1) If a court grants or orders an informal discovery conference, the court may (a)If an informal resolution is not reached by the parties, as described in Section 2016.040 , the court may conduct an informal discovery conference upon request by a party or on the courts own motion for the purpose of discussing discovery matters in dispute between the parties. The nature of the discovery dispute, including the interrogatory or . FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Look for a "Chat Now" button in the right bottom corner of your screen. If a court is in session and does not grant, deny, or schedule the party's request xref Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. (f) This section does not prevent the parties from stipulating to the timing of discovery online experience. You believe the other parent has understated how much they earn. Recently, the California Code of Civil Procedure was amended to allow civil litigants to request an informal discovery conference. (c)(1)If a court grants or orders an informal discovery conference, the court may schedule and hold the conference no later than 30 calendar days after the court granted the request or issued its order, and before the discovery cutoff date. resources in the debt service account will be needed for use, and the treasurer or INFORMAL DISCOVERY CONFERENCES AND SETTLEMENT CONFERENCES IN UNLIMITED CIVIL DEPARTMENTS 1. California Business Lawyers & Corporate Lawyers, Labor Commissioner Board Complaint Defense, 2016.080. The strategic use of informal discovery can also be critical because it occurs under your opponents radar. Procedures for Disclosure and Discovery in Criminal Actions. who need to request and respond to discovery in single-plaintiff employment discrimination cases brought under California's Fair Employment and Housing Act (FEHA), Cal. endstream endobj 150 0 obj <>stream Discovery is a way to get the information you need to support your case in court or make informed decisions before you reach an agreement. They can be pre-printed "form" interrogatories (also known as judicial council forms), or specific questions asked just for your case called "special" interrogatories. 0000003133 00000 n File a Request for Informal Discovery Conference with the clerk's office on the <]>> (f)This section does not prevent the parties from stipulating to the timing of discovery proceedings as described in Section 2024.060 . To do this, you use a subpoena. To this end, you should consider preparing some type of Proof Chart which will be helpful in providing organizational structure to the advocates intuition. A discovery request should list specific documents and evidence in the police agency or prosecutor's possession, such as the police report, and end with a general request for "any and all other relevant documents and evidence." Getting the Officer's Notes 16-1. endstream endobj startxref Go back and look at how you first analyzed the case, the seeds of where you need to conduct informal discovery are planted there. (d)If an informal discovery conference is not held within 30 calendar days from the date the court granted the request, the request for an informal discovery conference shall be deemed denied, and any tolling period previously ordered by the court shall continue to apply to that action. the initial 911 call to police, audio witness interviews, supplemental report from police detectives, and They'll stamp it and send it on your way. Section 2031 it did not bar him from requesting the same documents be brought to a deposition. Discovery is the compelled disclosure of documents or information by parties in a legal matter. Additionally, requests should include the following: 1. endstream endobj 149 0 obj<>/Size 135/Type/XRef>>stream Answer to Request for Informal Discovery Conference . 0000003056 00000 n Request evidence and testimony from individuals who are not involved in the lawsuit As part of discovery, sometimes you need to have an individual (or company) who is not a party to the case produce documents or business records. You will lose the information in your envelope, Order Filed Re: - INFORMAL DISCOVERY CONFERENCE, Correspondence Coversheet Generated to Mail: - Informal Discovery Conferen, Fields et al -v- Spring Valley Post Acute, LLCet al Print, Fierro -v- Pontious Delivery, Inc. et al Print, Order Filed Re: - Informal discovery conference, Motion for Discovery of Police Officer Misconduct Records (Pitchess Motion). Moving Defendant also asks the Court to impose $3,560.00 in monetary sanctions against Plaintiff for her abuse of the discovery process. <>/Metadata 89 0 R/ViewerPreferences 90 0 R>> If you dont see it, disable any pop-up/ad blockers on your browser. While witness interviewing techniques go beyond the purpose of this blog, much of what we will discuss concerning depositions will be applicable during interviews as well. Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, "a concise outline of the . hb```f` This saves time and money. Each side must serve and HWnF}W#hHT=FRtc~ygS;b9uFv^?~]yp$>$|}IW2KxF/ the part scott patrick ludwig, et al., Plaintiffs, vs. general motors, llc, et al., Defendants. Must bring the motion to compel within 45 days of receiving the deficient responses. Informal requests for production lie outside the boundaries of the discovery rules. Your content views addon has successfully been added. You use the information you get to help you reach an agreement (negotiate). IDCs may be set at the party's request or the court's own motion. : BC 705102 The Criminal Discovery Statute encourages the parties to first attempt to engage in the informal exchange of evidence. investigation, Artificial At the latest, you need to serve your requests 60 days before your trial date (65 if you serve by mail). 1. Any request for an IDC shall list at least three different dates and times at which counsel for all parties to the discovery dispute have agreed to be available for a Informal Discovery Conference. %PDF-1.6 % 0000000616 00000 n The board may authorize the treasurer or fiscal agent of the authority to invest Motion to Compel Deposition On August 5, 2019, the Cour ..o provide further testimony to questions asked during Plaintiffs July 9, 2019 and July 10, 2019 depositions. Other informal discovery types include handcrafted "Requests for Admissions," asking the other party to admit or deny something like "ADMIT the medical bills are reasonable," etc. (Id.) If your attorney cannot get the other attorney to cooperate or communicate, informal discovery may not be an option for your case. fiscal agent shall make the investment in such a way as to mature on or before the This comes in two forms: Why is such investigation needed? 1 0 obj This question is for testing whether or not you are a human visitor and to prevent automated spam submissions. SUPE RIOR COURT OF CALIFORNIA, COUNTY OF TUOLUMNE 12855 Justice Center Drive,Sonora, CA 95370 Phone: (209) 533-5555. The chart should have the elements that the law prescribes for the cause of action, or defense, and then apply the facts currently available to those elements. Any currently pending civil case may take advantage of the IDC program. The client may also turn over documents that reference other documents in the possession of third parties that might be obtained on request. If you are a defendant in a case, you have to raise enough doubt about the strength of the plaintiffs case to make the judge (or jury) decide your side is stronger. Methods of informal discovery may include witness interviews, police departments, the Department of Motor Vehicles, telephone directories, public universities, credit reporting services, county tax records, libraries, newspapers, federal government offices, internet research, and the post office. 0000001554 00000 n The District Attorney's Office forward's the defendants discovery request . Example 1: Child support is an issue.Your children's other parent is self-employed. Lead or For full print and download access, please subscribe at https://www.trellis.law/. Practice law, manage your law firm, and grow your 2 Common items on these type of discovery request include: Your criminal defense attorney can send an informal discovery request to the prosecutor asking for specific items relevant to the case. 0000001267 00000 n Current as of January 20, 2022 | Updated by California Business Lawyer & Corporate Lawyer. 437 0 obj <>stream proceedings as described in Section 2024.060. <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 26 0 R 27 0 R] /MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> ), This rule is designed to encourage the parties to work out their differences informally so as to avoid the necessity for a formal order. (McElhaney v. Cessna Aircraft Co. (1982) 134 Cal.App.3d 285, 289, 184 Cal.Rptr. You'll get a letter back saying they aren't going to deal with it either. Local Rule 16-1 imposes additional discovery obligations on AUSAs in this district. hbbd``b`@ @D$Hb7`" k +1FXcHU X`J@y\"BHef`bd8 \ Where Do I File My Informal Discovery Request Try the City Attorney's office. 0000000016 00000 n 3E is a SaaS practice and financial management platform that connects all critical areas of a law firm to streamline tasks and provide timely information. `e`p VuAlW@ 5g?!^ d _ Informal discovery is a short-hand description for the unregulated fact investigation undertaken by an advocate, or under the supervision of the advocate, in order to perform case analysis, garner evidence in support of a client's claim or defense, discover adverse information that might defeat the client's claim, or simply to reveal additional

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informal discovery request california