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Code of Civil Procedure 2030.060(d) provides, Each interrogatory shall be full and complete in and of itself. If a specially prepared interrogatory requires the responding party to review another document to respond, this is an appropriate opportunity to assert this objection because the subject interrogatory is not full and complete in and of itself. (See Laddon v. Superior Ct. (1959) 167 Cal.App.2d 391, 395-96 [plaintiffs discoverable interest in defendants liability insurance arises with the very pendency of the action against the insured. Cases | California Civil Discovery Resource Center This website uses cookies to improve your experience while you navigate through the website. Showing that we will not permit our clients to be intimidated or be taken advantage of and that we will not back down is essential to achieving the best results possible for our clients. Written discovery is a powerful tool as it forces the other side to provide information regarding their case under oath. 6 Grounds for Objecting to Requests for Admission - CEB WebObjecting to the discovery requests on relevance or privilege grounds. They may render discovery unmanageable.Another concern is that conditional discovery responses may lead to increased motion practice during discovery. 587, 593); and (2) defendants policies require a report regardless of whether plaintiff brought a lawsuit (See United States v. ChevronTexaco Corp. (N.D. Cal. Discovery In one of our cases, documents were (probably mistakenly) produced that contained the investigators sub rosa reports, which contained references to video surveillance. in case law. 1998) 134 F.3d 1194, 1202.) However, those repair records are a vital part of building your damage evidence for trial. Right to Privacy in California and Federal Discorvery (See e.g., Eldorado Savings & Loan Assn v. Superior Court (1987) 190 Cal.App.3d 342, 346; Heda v. Superior Court, (1990) 225 Cal.App.3d 525, 530; Britt v. Superior Court (1978) 20 Cal.3d 844, 863.) California Civil Discovery Resource Center An example of this type of interrogatory is: Please state whether you were stopped or driving through the intersection at the time of the motor vehicle accident..