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Discovery

Civil Litigation

Digital Discovery

Rules 26b and 34 of the Federal Rules of the Federal Rules of Civil Procedure instruct that information stored on computers is discoverable under the same rules that apply to tangible, written materials.[1] According to Principle 12 of The Sedona Principles:[2] Absent party agreement or court order specifying the form or Read more…

By Steve Simas, 7 yearsApril 26, 2016 ago
Civil Litigation

Procedural Grounds for Opposing a Motion

When a party or attorney is confronted by a motion by the opposing party or opposing counsel, the primary focus is usually on what they are attempting to accomplish. And that is absolutely appropriate – what if upon review you determine that your client does not oppose or actually agrees Read more…

By Steve Simas, 8 yearsMay 22, 2015 ago
Uncategorized

Avoiding Discovery Sanctions through Non-Oppositions

Hypothetical Plaintiffs serve discovery requests for special interrogatories and production of documents on your clients, the Defendants. At the time, you had just undergone a planned surgery and thus were in no shape to be able to timely respond. As a result, you request and are granted several extensions to Read more…

By Steve Simas, 9 yearsMarch 17, 2014 ago
Uncategorized

Greyhound Rules for Protective Orders

A protective order is a means by which the court shields a party, deponent, or other natural person or organization from “unwarranted annoyance, embarrassment, or oppression, or undue burden and expense.”  In the context of litigation, it is often used by the parties to limit the scope, frequency or method Read more…

By Steve Simas, 9 yearsFebruary 6, 2014 ago
Uncategorized

Service by Notice and Acknowledgement

Service by Notice and Acknowledgement of Receipt (Code Civ. Proc. § 415.30) is the recommended method of serving a summons on a known-to-be represented party or an unrepresented party who you believe to be amenable to such service. This then alleviates the need to track down the party and engage Read more…

By Steve Simas, 10 yearsJuly 25, 2013 ago
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Sacramento Office

Senator Hotel
1121 L Street, 7th Floor,
Sacramento, CA 95814
Tel. 916.789.9800
Fax. 916.789.9801

San Jose Office

Community Towers
111 North Market Street, Suite 300
San Jose, CA 95113
Tel. 408.357.8072
Fax. 408.357.8073

San Luis Obispo Office

354 Pacific Street
San Luis Obispo, CA 93401
Tel. 805.547.9300
Fax. 805.547.9302

San Diego Office

600 West Broadway, Suite 700
San Diego, CA 92101
Tel. 619.961.4998
Fax. 619.961.4999

Santa Monica Office

2450 Colorado Avenue, Suite 100E
Santa Monica, CA 90404
Tel. 424.268.8818
Fax. 424.268.8828

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