CA Trust, Estate & Probate Litigation

CA Trust, Estate & Probate Litigation

Category Archives: Discovery

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Don’t Let Defense Attorneys Direct Their Clients Not to Answer Questions at Deposition–Bring a Motion to Compel

Posted in Discovery
I’m still amazed when defense attorneys direct their clients not to answer my questions during a deposition where no privilege exists. In other words, the defense attorney simply assumes the role of judge and decides what questions their client will and will not answer. Of course, the defense attorney instructs their client not to answer… Continue Reading

Give me your facts: Why Form Interrogatory 15.1 is the most important discovery question in California

Posted in Discovery
California Form Interrogatory 15.1 (an “interrogatory” is just a question) is the most important interrogatory to serve on your opposing party in a lawsuit. And the law requires they answer it fully and completely. Yet, so many attorneys refuse to answer the question properly. A typical use of 15.1 follows: You file a Trust Contest… Continue Reading
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