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Discovery and Discovery Motions

Discovery

California Judicial Council Form Employment Interrogatories, submitted by the California Judicial Council. These are the form employment interrogatories adopted effective July 1, 2002.

First Interrogatories, submitted by Phil Horowitz.

First Request for Production of Documents, submitted by Phil Horowitz.

First Request for Production of Documents, submitted by Jim Stoneman.
Click here to download in WordPerfect format intead.

Notice of Deposition With Production of Documents , submitted by Phil Horowitz.

Proposed Stipulation and Protective Order, Medical Records , submitted by Phil Horowitz.

Cover Letter for Proposed Stipulation and Protective Order, submitted by Phil Horowitz.

Joint Report of Early Meeting of Counsel and Initial Disclosure, submitted by Michelle Reinglass. Papers complying with federal court early meeting and initial disclosure rules.

New California Legislation for Using New Technology in Discovery, submitted by the Hon. Richard E. Best. This article explains the new California legislation facilitating the use of new technology in discovery, including appearance at deposition by Internet or video conference and service by e-mail.

Electronic Discovery Preservation Duty and Spoliation, submitted by the Hon. Richard E. Best. This article explains the duty to preserve electronic evidence (such as e-mail and other information stored on computers) and remedies for spoliation, with exhaustive California case citations.

The Need for Electronic Discovery Rules, submitted by the Hon. Richard E. Best. This article explores the need for rules governing discovery of computerized information. Topics include how thorough a search the responding party must make, formatting and reviewing the data, and cost allocation.

Discovery Motions

Motion to Quash Personnel File Subpoena: Current Employer, submitted by James Johnston. The defendant in this case subpoenaed plaintiff's complete personnel file from current employment. This motion to quash explains why the files are not discoverable.
Click here to download in Word format intead.

Motion to Quash Multiple Personnel Files Subpoenas, submitted by James Johnston. This motion seeks to quash subpoenas of plaintiff's personnel files from both his current and prior employers.
Click here to download in Word format intead.

Motion to Compel, submitted by Sheila Thomas, ERA Director of Litigation. Motion to compel employer to comply with pattern and practice discovery requests made in an employment discrimination case. Also addresses potential liability of parent corporation.

Motion to Compel, Reply Brief, submitted by Sheila Thomas, ERA Director of Litigation. Reply brief for motion to compel employer to comply with pattern and practice discovery requests made in an employment discrimination case. Includes extended discussion of potential liability of parent corporation.

Motion for Federal Court Discovery Sanctions, submitted by Sheila Thomas, ERA Director of Litigation. Motion for sanctions against employer for opposition to pattern and practice discovery in employment discrimination case.

Reply on Motion for Federal Court Discovery Sanctions, submitted by Sheila Thomas, ERA Director of Litigation. Reply on motion for sanctions against employer for opposition to pattern and practice discovery in employment discrimination case.

Motion to Compel Production of Financial Documents for Punitive Damages Claim, submitted by Harvey Berger.

Motion for Post-Trial Discovery re: Alter Ego, submitted by Robby Robinson. After a plaintiff's jury verdict, defendant declared bankruptcy. Here is the post-trial motion, points and authorities and reply brief for leave to take discovery to establish others as liable alter egos.
Click here to download in WordPerfect format intead.

California Employment Lawyers Association   •   Phone: (818) 703-0587   •   Fax: (818) 703-0591