opposition to motion to compel california separate statement

Agencies are, and properly should be, engaged in a continuing process of examining their policies; this process will generate memoranda containing recommendations which do not ripen into decisions; and the lower courts should be wary of interfering with this process. The separate statement must include--for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested--the following: (Cal. The eight documents referred to in paragraph 3 above contain analyses of and recommendations by Antitrust Division economists and attorneys to their superiors during the deliberations leading up to issuance of the Policy Statements. A five-page handwritten report of statistics on hospital closings from 1988 to 1991. A two-page May 25, 1993 draft paper discussing possible safe harbor for hospital mergers. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Your subscription was successfully upgraded. If you wish to keep the information in your envelope between pages, Eight of these documents are described in the confidential Schedule to this Declaration, which will be submitted to the Court in camera. Moreover, it is protected from discovery by the intragovernmental deliberative process privilege, as set forth in the Declaration and Claim of Privilege of Acting Assistant Attorney General Robert E. Litan, which is attached as Exhibit 3. MOTIONS Disclosure of the tables, maps, statistics and numerical information would reveal the thinking of staff as to which facts were relevant to the deliberations leading up to issuance of the Policy Statements. (See, e.g., Code Civ. Proc., Your subscription has successfully been upgraded. We are currently collect data for this state. Defendants have moved for an order regarding Document Requests 4, 7, and 13 to which the United States lodged objections. The discovery request was too vague or ambiguous. 1311-1314. . (6) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document. The first safety zone applies to hospital mergers satisfying certain criteria. Defendants have limited Request 13 from its previously broad scope. (Code Civ. R. Civ. Except as provided in 3.1345(b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. In accordance with 28 U.S.C. ( Code Civ. In order to ensure effective and sound policy-making, the staff and officials of the Antitrust Division must remain free to engage in a candid exchange of views concerning proposed policies. Opposition to Motion to Compel Discovery - California Los Angeles Superior Court of California December 31, 2022 Opposition to Motion to Compel Discovery Superior Court of California Los Angeles Timing 9 Court Days Before the Hearing All opposition papers must be filed and served at least 9 court days before the hearing. will be able to access it on trellis. If you wish to keep the information in your envelope between pages, The text of the request, interrogatory, question, or inspection demand; The text of each response, answer, or objection, and any further responses or answers; A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and, If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.. The deliberative process privilege also protects from disclosure the draft document (number 8 on the Confidential Schedule) that could have developed, but did not, into an explanation of the Policy Statements. by 3. Therefore, Plaintiffs respectfully request that this Court deny Defendant's Motion to Compel Arbitration and Stay Proceedings ("Motion"). 2071 and Fed. vs University of the Pacific, a California Corporation et , ORDER DENYING DEFENDANT'S MOTION TO COMPEL FURTHER DISCOVERY RESPONSES UND, JON LOUIS VS. ST FRANCIS BAY -ONE HUNDRED ONE CRESCENT WAY et al, Motion to Compel Further Responses to Special Interrogatorie - From Defend, DOE -V- SAN BERNARDINO CITY UNIFIED SCHOOL Print, MOTION TO COMPEL FILED RECORD SEALED - Plaintiff Mishelle Neverson's Motio. Material must not be incorporated into the separate statement by reference. HEARING DATE: When can you file a opposition to a motion to compel in California Oppositions to motions to compel must be filed no later than 9 days before the hearing. (2) Defendants now seek three categories of documents related to the safety zone for certain hospital mergers set forth in the Policy Statements: (1)Senior Officials' Communications; (2)"Post-decisional" documents which reflect "summaries, comments, investigations, explanations, interpretations, applications, analysis or implementation of" the safety zones; and (3)Numerical data and tabulations. Please write more! Defendants have moved for the Court to compel production, among other documents, of all tabulations, accumulations of data, and other statistical or numerical information relating to the safety zone for hospital mergers contained in the Policy Statements. That request focused solely on pre-decisional documents and unquestionably invaded the intragovernmental deliberative processes of the Antitrust Division. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; References. Ask for a copy. when new changes related to " are available. (CCP 2030.300) (CCP 2030.300) Prepare the Motion You must file a separate motion for each of the discovery responses you wish to compel. 1978), the NLRB had compiled a "statistical report which contains no subjective conclusions, and, as a result, must be considered 'purely factual' in nature." The court denied the motion to compel arbitration, finding that the procedural provisions of the California Arbitration Act (CAA), rather than those of the FAA, applied to its ruling on the motion.Under section 1281.2, 1 The Agreement is a standard form created and distributed by the California Association of Realtors (CAR). Defendant further requests $2,365 in monetary sanctions. The privilege protects the process of separating significant facts from the insignificant. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. vs City of Escalon et al. 1986) (rejecting request for discovery). Your recipients will receive an email with this envelope shortly and Discovery should not be permitted under these circumstances. Sample Opposition to Motion to Compel Further Responses to Documents for California, This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are , 100% found this document useful (4 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Supgrkar Caurt al tng Stftg al Cfiklarjkf, Ta suhscrkhg ta `y LXGG wggeiy igmfi jgwsigttgr vkskt, Ta vkgw avgr 3 sf`pig igmfi dacu`gjts said hy !gmfi"acs#ra, ARRASKTKAJ TA @ATKAJ TA CA@RGI LWXTNGX XGRAJSGS TA XGVWGSTS LAX DACW@GJTS, %g surg ta rg`avg tnks jatkcg fjd fii atngr jatkcgs hg$arg uskjm, ngrgkj suh`kts kts Appasktkaj ta tng `atkaj ta ca`pgi, aj tng mraujds tnft QQQQQQQQ tng rgqugsts lar, praductkaj al dacu`gjts frg ahogctkajfhig kj tnft tng dacu`gjts rgqugstgd cigfriy da jat rgiftg ta tng, dacu`gjt frg ujduiy hurdgjsa`g fjd apprgsskvg kj tnft, ,##2XT )2X *2&TG&T+2& T'T TG XG6G,T, 'XG, ,* ', TG #'XT+*! 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