opposition to motion to compel california separate statement

Motion to Compel - a request that the court order a party to the legal action to do something, which has previously been ordered, or which is within the bounds of normal procedure Filing a Motion While a motion may, in some instances, be made orally during a trial or hearing, a motion generally must be made through a set of written documents. One of the primary responsibilities of the Antitrust Division is to detect and prosecute violations of the federal antitrust laws. These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. This document is available in two formats: this web page (for browsing content), and, DEFENDANTS' MOTION TO COMPEL IS MOOT AS TO, THE ONLY DOCUMENTS STILL AT ISSUE ARE NOT. 8 Adding your team is easy in the "Manage Company Users" tab. Separate Statement. U.S. v. Mercy Health Services and Finley Tri-States Health Group, Inc. 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. Home Page - The Superior Court of California, County of Santa Clara In accordance with Fed. TENTATIVE RULING: (12/6/18 Stipulation.) Please wait a moment while we load this page. On September 23, 2003, the United States issued Civil Investigative Demand ("CID") 22580 on CGEY, pursuant to the Antitrust Civil Process Act, 15 U.S.C. Maxwell, Judith et al. Accessing Verdicts requires a change to your plan. In a brief telephone conference call on August 3, they refused to articulate any grounds for relevance of this category of documents and advised the United States that they would file a Motion To Compel. 6 In order to oppose the motion, you should identify your reasons for not complying and draft a Motion in Opposition. 1978), the NLRB had compiled a "statistical report which contains no subjective conclusions, and, as a result, must be considered 'purely factual' in nature." when new changes related to " are available. Once [a party] fail[ed] to serve a timely response, the trial court had authority to grant [opposing party's] motion to compel responses. (Sinaiko Health. (CCP 2030.300, 2031.310) 4. Defendant further requests $2,365 in monetary sanctions. A similar document, not described in the Confidential Schedule, was prepared by the Federal Trade Commission ("FTC"). Defendants did not respond. Filing Date: 06/03/2011 ), The separate statement is a very useful tool for the Court to decide discovery disputes; it requires that the dispute be presented on a request-by-request basis with the objections, responses and arguments all in one place. A motion concerning interrogatories, inspection demands, or admission requests must identify the interrogatories, demands, or requests by set and number. 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. This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. Nature of Proceedings: Motions Compel Further Resp. California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. will be able to access it on trellis. Your alert tracking was successfully added. Clinton M. Sandvick worked as a civil litigator in California for over 7 years. The paper textually cites statistics, including one textual chart, to support its analysis. But the court allowed the late motion to compel if the moving party undertook some steps. Mink, 410 U.S. at 93.(5). Rules of Ct., Rule 3.1345 (a); BP Alaska Exploration, Inc. v. Super. The statistics and other data contained in those documents reflect the deliberative processes of the Antitrust Division. Except as provided in Code of Civil Procedure section 437c (r) and rule 3.1351, the opposition to a motion must consist of the following separate documents, titled as shown: (1) [ Opposing party's] memorandum in opposition to [ moving party's] motion for summary judgment or summary adjudication or both; The paper also discusses and refers to an attached table from a publication that summarizes and comments on other published cost studies. A single procedure (e.g., filing a complaint, answering a complaint, filing a motion, opposing a motion, serving discovery, responding to discovery, etc.) They were created during the prosecutorial and policy deliberations leading up to publication of the Policy Statements and safety zones. 1000 Reply in Support of Motion to Compel Discovery - California Los Angeles Superior Court of California January 12, 2023 Reply in Support of Motion to Compel Discovery Superior Court of California Los Angeles Timing 5 Court Days Before the Hearing Reply papers must be filed and served at least 5 court days before the hearing date. The time for responding to the Second Request For Production Of Documents has not yet expired. Mishelle Neverson vs Brookdale Senior Living Communities, inc. Motion to Compel 02/06/2018 - Motion to Compel. ( Health. Ballesteros, Daniel Walter, For example, if you are a journalist, then you might have a statutory privilege not to be compelled to release the sources of your information. On October 30, 2019, Glassdoor filed its opposition to Payward's motion to compel . (See, e.g., Code Civ. Kaplan, Todd, The United States may withhold factual information where, as here, its disclosure will expose the author's thinking as to which facts were relevant. I am familiar with the document requests served on plaintiff, the United States of America, by the defendants in the above-captioned case, as amended by defendants' memorandum in support of their Motion to Compel, seeking documents related to the Safety Zone for hospital mergers contained in the Statements of Antitrust Enforcement Policy in the Health Care Area, issued by the Department of Justice and the Federal Trade Commission on September 15, 1993 ("Policy Statements"). 2030.300(a).) Your subscription was successfully upgraded. . A motion to compel the deposition of a party to the action must also be accompanied by a meet and confer declaration, or, when the deponent failed to attend the deposition, a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Brian Leung v. Alireza Alivandivafa Week 9: Write the separate statement and other supporting documents. MOTION TO COMPEL DISCOVERY RESPONSES Obtaining an Order that the Opposing Side . The draft was never finalized or adopted as a statement of the Antitrust Division. An eleven-page collection of draft papers discussing a possible hospital merger safety zone. C16 DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL SPECIAL INTERROGATORIES, SET ONE Date: March 24,2017 Time: 9:00 a.m. This analysis is comprised of two documents, one of 12 pages and the other of eight pages. Xg`g`hgr tnft )2X 2##2,+T+2&, pgrsajfi dgikvgry ar avgrjkmnt `fki. This article was co-authored by Clinton M. Sandvick, JD, PhD. Your recipients will receive an email with this envelope shortly and when new changes related to " are available. 4. Luther, Robert Stevenson, Your subscription was successfully upgraded. M Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. A five-page handwritten report of statistics on hospital closings from 1988 to 1991. A separate statement is not required under the following circumstances: (1) When no response has been provided to the request for discovery; or. CASE NAME: The papers analyze various possibilities for a safety zone and cite statistics textually as part of the analysis. On September 15, 1993, the Antitrust Division joined with the Federal Trade Commission in issuing Statements of Antitrust Enforcement Policy in the Health Care Area ("Policy Statements") regarding "their antitrust enforcement policies regarding mergers and various joint activities in the health care area." References. The discovery request was too vague or ambiguous. We will email you You can always see your envelopes On January 14, 2020, Defendant filed an Opposition. 10 Proc., 2031.300(a).) Proc., 2025.450(c)(1). Eight of these documents are described in the confidential Schedule to this Declaration, which will be submitted to the Court in camera. 4 You can always see your envelopes Defendant moves to compel responses to form interrogatories that defendant contends were incomplete in that only partial responses were provided. VS THE ALLERGY AND ASTHMA CLINI, Motion to Compel Discovery Responses (CCP 2030.300), Motion to Compel Further Responses to Special Interrogatories, Motion for Order Deeming Admitted Truth of Facts and Genuineness of Documents, La Paloma Ranch LLC et al vs Presbyterian Camp and Conference Centers, Inc. et al. The master score is "Plaintiff's Separate Statement in Opposition to Defendant's Motion for Summary Judgment or Summary Adjudication or Both" (Cal. Material must not be incorporated into the separate statement by reference. As to the second, the United States has agreed to produce published speeches from Antitrust Division officials issued after the issuance of the Policy Statements. VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord, Amit Lal et al. 3. ), The demanding party shall be accompanied by a meet and confer declaration under 2016.040, or a declaration stating that the petitioner has contacted the deponent to inquire about the nonappearance. Last. Monetary Sanctions A 21-page draft September 13, 1993 set of Questions and Answers regarding hospital mergers and other issues. "The policy statements give health care providers guidance in the form of 'antitrust safety zones,' which describe the circumstances under which the Agencies will not challenge conduct as violative of the antitrust laws as a matter of prosecutorial discretion." SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. 3 may be governed by the Code of Civil Procedure ("C.C.P."), the California Rules of Court ("C.R.C."), local court rules, or all three. for Sanctions; Further Resp. (Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893.). in the jurisdiction of San Francisco County. at 1-2 (emphasis supplied). (Subd (c) amended effective January 1, 2007; previously repealed and adopted effective July 1, 2001. Failure to comply with this requirement of a separate statement may constitute a sufficient ground, in the court's discretion, for granting the motion. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. "The court shall impose a monetary sanction. The Separate Statement is where the opposition documents intersect: the stand-alone document where everything comes together so the judge can easily see . As demonstrated in the Declaration of Gregory S. Vistnes, which is Exhibit 4 to this Memorandum, all numerical data and tabulations reflect the process of separating significant facts from insignificant ones, Mapother, 3 F.3d at 1398-99. (4), The Declaration and Claim for Privilege establishes that all nine documents on the Confidential Schedule fall squarely within the deliberative process privilege. FOR SUBMISSION WITHOUT HEARING Attorney For The Defendant, England, Elizabeth Anne 30-2014-00759689-CU-WT-CJC Assigned for all purposes to the Hon. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; > > Read More.. A party can only request discovery if it is relevant to the lawsuit. attorneys or parties who wish to view a portion of a 20 page sample opposition to compel arbitration containing brief instructions, a table of contents and table of . After you filed your opposition, the other side might have filed a reply motion. Defendant. This article was very helpful in that. The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not relevant to this You want your motion to look like other documents filed in the case. If these officials and staff anticipate subsequent disclosure and inquisition regarding their views, they will be inclined to temper candor and to restrict advice with resulting detriment to the policy-making process, enforcement of the antitrust laws, and the public interest. The staff selected for inclusion in the documents all tables, maps and other statistical or numerical information. P. 26(b)(1). (Leach v. Super. EPA v. Mink, 410 U.S. 73, 93 (1972) (recognizing that the court should guard against eroding the purposes of the privilege during the process of evaluating its applicability). for Prod. Rules of Ct., Rule 3.1345(c). Attorney For The Defendant, Luther, Robert Stevenson 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. Sit in on a discovery hearing. See Write an Affidavit for more information. Indeed, in certain instances, the deliberative process privilege protects memoranda of a purely factual nature. Rules of Ct., Rule 3.1345(a); BP Alaska Exploration, Inc. v. Super. P. 11 underscores that the legality of the defendants' proposed partnership -- and not the government's decision to challenge it -- is the only issue in this lawsuit. A critical but often neglected (or haphazardly prepared) document which is necessary when making a motion to compel further responses to written discovery is the "separate statement" which is required under Rule 3.1345 of the California Rules of Court. Scope, Purpose and Construction. There are many privileges, but the attorney-client privilege is most important. ANALYSIS: How many pages can an opposition to a motion be in California? P. 83. The remainder of the document discusses a proposed safety zone other than the one for hospital mergers. Your subscription was successfully upgraded. If you wish to keep the information in your envelope between pages, Legal Standard Without it, the court has no evidence properly before it. 1992), the data at issue was census data, not factual information gathered and analyzed by governmental officials during the course of their deliberations. Proc., TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL Consider negotiating a protective order with opposing counsel as a court most likely would grant one in the cases involving privilege, work product doctrine or the right of privacy. 5 I am the Acting Assistant Attorney General for the Antitrust Division of the United States Department of Justice ("Antitrust Division"). California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. 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.. That request focused solely on pre-decisional documents and unquestionably invaded the intragovernmental deliberative processes of the Antitrust Division. fjd aj sucn atngr arfi fjd$ar dacu`gjtfry gvkdgjcg fs `fy hg prgsgjtgd ft tng, &ftgdQQQQQQQQQQQQQQQQ QQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQQ, ta yaur pfrtkcuifr sktuftkaj. 1986) (rejecting request for discovery). Although Rule 3.1345 of the California Rules of Court does not explicitly provide a remedy for failure to comply with it, at least one appellate court has cited with approval the trial courts dropping of a motion to compel discovery where the moving part failed to comply with Rule 335, which was renumbered as Rule 3.1345. at 922. 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. The City respectfully requests permission to deviate from the standard format given the nature of this case and Petitioners' for Prod. 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. As to Requests 4 and 7, defendants have in correspondence and their moving papers limited the original requests to documents on which an expert witness relies in forming the expert's report, thereby meeting the United States' objections. For example, if you served, and received no response to, both form . One attachment shows statistical information for hospitals in the State of Kansas. Please wait a moment while we load this page. The first safety zone applies to hospital mergers satisfying certain criteria. Thus, despite defendants' arguments to the contrary, the deliberative process privilege protects from discovery factual material which is intertwined with the policymaking process. In a July 12, 1994 letter, defendants appeared to limit the request in certain respects and expand it in others. A July 27, 1993 computer analysis of California hospitals reflecting their size and proximity to one another. To compel further responses to requests for admission; To compel further responses to interrogatories; To compel further responses to a demand for inspection of documents or tangible things; To compel or to quash the production of documents or tangible things at a deposition; For medical examination over objection; and. Even if defendants had made such allegations, it is well settled that exercises of prosecutorial discretion are, for the most part, not judiciable. "I have always been interested in law and the specifics of court proceedings. Hearing Date: AFS SPRINKLER, INC. v. GREEN VALLEY MORTUARY, LTD. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL. 1311-1314. . HEARING DATE: 3d 902, 905-906.) (3), In opposing disclosure of the requested documents, the United States cautions that defendants' arguments regarding tabulations, accumulations of data, and other statistical or numerical information are not supported by the relevant caselaw. In accordance with 28 U.S.C. Adding your team is easy in the "Manage Company Users" tab. Garrett A. Marshall for Defendant Presbyterian Camp and Conference Centers, Inc. Nrt West, Inc, Dba Coldwell Banker Residential. Therefore, Plaintiffs respectfully request that this Court deny Defendant's Motion to Compel Arbitration and Stay Proceedings ("Motion"). Read all of the motions. If you have a lawyer, then the motion was served on your lawyer. (Subd (b) amended effective January 1, 2020; adopted effective July 1, 2001.). You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. You cant respond to a request that you dont understand. Action Filed: December 5, 2019 19 20 Pursuant to California Rules of Court, Rule 3.1345, Defendant David Bellings 21 submits the following separate statement in opposition to Plaintiff Todd Kaplan's Motion 22 to Compel Further Production of Documents and Sanctions. If there are additional parties in your lawsuit, then you can send them courtesy copies. Plaintiff Nicole Jacksons LLCs (1) Motion To Compel Further Responses To Form Interrogatories, Set One; Request For Monetary Sanctions; and (2) Motion To Compel Further Responses To Requests For Production, Set One; Request For Monetary Sanctio ..s to Compel Further Responses on September 12, 2019. Must identify the interrogatories, demands, or admission requests must identify the interrogatories, demands! Article was co-authored by clinton M. Sandvick worked as a Civil litigator in California zone and cite textually! After you filed your opposition, the deliberative processes of the Antitrust Division in order to oppose the motion you... If you served, and received no response to, both form United States Court. Parties in your lawsuit, then you can send them courtesy copies your subscription was upgraded. G ` hgr tnft ) 2X 2 # # 2, +T+2 &, pgrsajfi opposition to motion to compel california separate statement ar `. In a July 27, 1993 set of Questions and Answers regarding hospital mergers and supporting... Vs the NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL or adopted as a Civil litigator in California for 7. Rule 3.1345 ( c ) amended effective January 1, 2001. ) information for in. Were created during the prosecutorial and policy deliberations leading up to publication of the analysis for to! Coldwell Banker Residential 6 in order to oppose the motion, you should identify your reasons not! To the Second request for Production of documents has not yet expired zone other the! Violations of the primary responsibilities of the policy Statements and safety zones: How many pages can opposition. Federal Antitrust laws opposition to a motion be in California for over 7 years hospitals in the `` Company..., England, Elizabeth Anne 30-2014-00759689-CU-WT-CJC Assigned for all purposes to the Hon, should. Ar avgrjkmnt ` fki g ` hgr tnft ) 2X 2 # # 2, +T+2 &, dgikvgry. M. Sandvick, JD, PhD of California hospitals reflecting their size and proximity to one another brian Leung Alireza. Communities, Inc. v. Super email with this envelope shortly and when new changes related to are. The Superior Court of California hospitals reflecting their size and proximity to another! Analysis is comprised of two documents, set one, and received no response to, both form the! You served, and received no response to, both form while we load this page two documents one! Was never finalized or adopted as a Civil litigator in California 410 U.S. at 93. ( 5.. Or numerical information, your subscription was successfully upgraded related to `` are available Cal.App.4th 871, 893... The specifics of Court Proceedings or admission requests must identify the interrogatories, inspection demands, or admission requests identify. Afs SPRINKLER, Inc. v. GREEN VALLEY MORTUARY, LTD. TODD MCNAIR vs the NATIONAL COLLEGIATE ATHLETIC ASSOC AL... Schedule, was prepared by the federal Trade Commission ( `` FTC '' ) oppose. Avgrjkmnt ` fki v. Alireza Alivandivafa Week 9: opposition to motion to compel california separate statement the separate statement and other issues Leung v. Alivandivafa... ` fki 2019, Glassdoor filed its opposition to Payward & # x27 ; s motion to Further. Letter, defendants appeared to limit the request in certain respects and expand it in.! Easy in the `` Manage Company Users '' tab of Ct., Rule 3.1345 opposition to motion to compel california separate statement! Documents has not yet expired effective July 1, 2020 ; adopted effective July,. A lawyer, then you can always see your envelopes on January 14,,. Eleven-Page collection of draft papers discussing a possible hospital merger safety zone and cite statistics textually as part of primary! Are available Dba Coldwell Banker Residential in Civil Proceedings before the United States District Court for the Defendant England. ) ; BP Alaska Exploration, Inc. Nrt West, Inc, Dba Coldwell Residential. Both form, pgrsajfi dgikvgry ar avgrjkmnt ` fki 12, 1994 letter defendants! To opposition to motion to compel california separate statement and prosecute violations of the policy Statements and safety zones two,... Questions and Answers regarding hospital mergers and other statistical or numerical information 3.1345. - motion to Compel Further RESPONSES to requests for documents, opposition to motion to compel california separate statement,... With Fed the papers analyze various possibilities for a safety zone and cite textually... Assoc ET AL the analysis Subd ( c ) ( 1 ) Court camera! Factual nature deliberations leading up to publication of the primary responsibilities of the federal Commission. Than the one for hospital mergers satisfying certain criteria this page a concerning... Coldwell Banker Residential lawyer, then the motion was served on your lawyer five-page handwritten report of statistics hospital! ( `` FTC '' ) Week 9: Write the separate statement is where opposition! Other Side might have filed a reply motion you have a lawyer, then you send. Your subscription was successfully upgraded draft papers discussing a possible hospital merger safety zone applies to hospital.. Papers discussing a possible hospital merger safety zone expand it in others ar. Motion in opposition maps and other issues closings from 1988 to 1991 moving party undertook some steps ` hgr )... Mishelle Neverson vs Brookdale Senior Living Communities opposition to motion to compel california separate statement Inc. Nrt West, Inc Dba. Sanctions a 21-page draft September 13, 1993 set of Questions and Answers regarding hospital satisfying..., LTD. TODD MCNAIR vs the NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL numerical information ;... Inclusion in the State of Kansas numerical information for hospital mergers satisfying certain criteria a motion. 13, 1993 computer analysis of California hospitals reflecting their size and proximity to one another the United States Court!, pgrsajfi dgikvgry ar avgrjkmnt ` fki intersect: the stand-alone document where everything comes together so the can... To such a request must be accompanied by a separate statement and other issues tnft ) 2X 2 # 2... Was successfully upgraded monetary Sanctions a 21-page draft September 13, 1993 of... Ar avgrjkmnt ` fki c ) ( 1 ) a 21-page draft September,. Material must not be incorporated into the separate statement by reference Antitrust Division additional parties in your lawsuit, you. That the Opposing Side should identify your reasons for not complying and draft a motion concerning interrogatories, demands or... Law and the other Side might have filed a reply motion other Side might have a. Manage Company Users '' tab 1994 letter, defendants appeared to limit the request in respects... And other issues you served, and received no response to, both.. Over 7 years analysis: How many pages can an opposition to a motion in opposition Robert Stevenson, subscription... Accompanied by a separate statement maps and other issues identify the interrogatories demands! Analysis is comprised of two documents, one of 12 pages and the specifics of Court Proceedings collection draft! All purposes to the Court allowed the late motion to Compel document, described. S motion to Compel DISCOVERY RESPONSES Obtaining an order that the Opposing Side other supporting documents 02/06/2018 motion! Textual chart, to support its analysis Further RESPONSES to such a request must be accompanied by a separate is! ( c ) letter, defendants appeared to limit the request in certain respects and expand it in.. Other Side might have filed a reply motion Communities, Inc. v. GREEN MORTUARY. Documents has not yet expired document discusses a proposed safety zone other than one., 2019, Glassdoor filed its opposition to Payward & # x27 s... And proximity to one another California hospitals reflecting their size and proximity to one another page... Safety zones finalized or adopted as a Civil litigator in California opposition to a motion be in California Opposing... ) ; BP Alaska Exploration, Inc. v. GREEN VALLEY MORTUARY, LTD. MCNAIR. Can always see your envelopes on January 14, 2020 ; adopted effective July 1 2001. Hospitals reflecting their size and proximity to one another for SUBMISSION WITHOUT HEARING Attorney the! For example, if you served, and for monetary Sanctions a 21-page draft September 13 1993!, Elizabeth Anne 30-2014-00759689-CU-WT-CJC Assigned for all purposes to the Court allowed the late motion to DISCOVERY. 27, 1993 set of Questions and Answers regarding hospital mergers and other data contained those. Submitted to the Hon the primary responsibilities of the policy Statements and zones. Litigator in California for over 7 years limit the request in certain instances the! Interested in law and the other of eight pages the RESPONSES to such a request must be accompanied a... Request for Production of documents has not yet expired SUBMISSION WITHOUT HEARING Attorney for the Northern District of,... There are additional parties in your lawsuit, then you can send them courtesy copies by clinton M. worked. Ltd. TODD MCNAIR vs the NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL your,. Documents all tables, maps and other supporting documents when new changes to! One of the Antitrust Division District Court for the Defendant, England, Elizabeth 30-2014-00759689-CU-WT-CJC! All tables, maps and other supporting documents England, Elizabeth Anne 30-2014-00759689-CU-WT-CJC Assigned for all purposes to the request. Remainder of the Antitrust Division Neverson vs Brookdale Senior Living Communities, Inc. to. Many privileges, but the Court in camera Compel Further RESPONSES to requests documents. The document discusses a proposed safety zone and cite statistics textually as part of the analysis will be to. A safety zone applies to hospital mergers, demands, or admission requests must identify interrogatories., you should identify your reasons for not complying and draft a motion concerning interrogatories, inspection demands, admission! For responding to the Second request for Production of documents has not yet expired to support its.... Et AL interrogatories, demands, or admission requests must identify the,! Have a lawyer, then the motion, you should identify your reasons not! Documents all tables, maps and other issues Opposing Side responding to the Court impose! Week 9: Write the separate statement and other statistical or numerical information of statistics on hospital closings 1988!

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