"motion to compel"

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The most important interrogatory in California is Form Interrogatory 15.1. Propound it; meet and confer on it; file motions to compel on it. Make them give you their facts, witnesses, and documents supporting their denials and affirmative defenses. Form Interrogatory 15.1 is the great equalizer in California trust and probate litigation.

Responding to written discovery can be overwhelming. In most cases defense attorneys send the bulk of written discovery early on in a lawsuit. This discovery generally includes Form Interrogatories, Special Interrogatories, Requests for Admission, and Demands to Produce. Due to the size and expansive scope of this discovery one can become overwhelmed by it and…

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…