Human Trafficking Caseworker-Victim: Evid.Code 1038-1038.2. All Rights Reserved. The above is an example of inappropriate boilerplate objections. If a party to whom a demand for inspection, copying, testing, or sampling is directed fails to serve a timely response to it, the following rules shall apply: (a) The party to whom the demand for inspection, copying, testing, or sampling is directed waives any objection to the demand, including one based on privilege In particular, the judge disagreed with Frank's objection tom the $2.5 million in attorney fees requested in the settlement and criticized a "flippant response" his attorney made in court. The inspection is for determining the condition of the property and makes sure that the property is free from safety issues and ready to move in. After pioneering the field nearly three decades ago, were continuing to redefine medical expert witness services by providing value far beyond a referral alone. Relevancy may vary with size and complexity of the case and must be considered with regard to the burden and value of the information sought (among other factors). Our medical expert witnesses leave no doubt. 2017.010. You can't base the levels of radon in your house after what your neighbor's levels are, eitherthey are completely different. Personal injury and medical malpractice lawyers do not have to wait for a trial to make evidence objections. Calls for Legal Reasoning: Sav-On Drugs v. Sup. q $ "O/(
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U!o%;7 Ct.(1962) 58 C2d 210,218. When an attorney in California cannot predict how a court will deal with objections, it is risky not to make evidence objections or not answer objections when the opportunity arises. If you could sell the house to someone else for the same price with the same issues, it's probably not wise to make the repairs. Using discovery to reach evaluation, mediation and trial goals, One of the most common questions I am asked is: when does the clock start regarding bringing motions to compel written discovery? Personal injury and medical malpractice lawyers do not have to wait for a trial to make evidence objections. The seller doesn't usually fix asbestos because the house itself is safe as long as it stays undisturbed. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2031-300/. United States District Court Central District of California Philip S. Gutierrez, Chief Judge Kiry K. Gray, District Court Executive/Clerk of Court. This Blog/Web Site is made available by the lawyer or law firm publisher for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. Odds are good, however, that if SB 17 is well received, legislation to make compulsory its disclosure procedures, including an ongoing duty to supplement, will be introduced in a future legislative session. , here isalist of proper and improper objections to deposition questionsthat you should also keep in the back of your legal pad. Responding party objects to this request as it does not seek relevant documents or documents reasonably calculated to the discovery of admissible evidence. /T 61247
Yet, less tailored requests may allow the responding party to simply identify each document as responsive to that request, eliminating any possible benefit to offset the cost of the amplified discovery made more likely by SB 370. <<
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Continue Reading DISCOVERY GAMES AND MISCONCEPTIONS Is the Court Correct That There is No Motion to Strike in Discovery? Continue Reading WHY THESE OBJECTIONS ARE GARBAGE. SB 370: New document identification requirement in all active cases, SB 370 provides that "[a]ny documents or category of documents produced in response to a demand for inspection, copying, testing, or sampling shall be identified with the specific request number to which the documents respond.". (b) The party making the demand may move for an order compelling response to the demand. %%EOF
For further information about these entities and DLA piper's structure, please refer the, Litigation, Arbitration and Investigations, New California laws make potentially costly changes to Civil Discovery Act, Whether and how documents responsive to multiple requests must be identified, The extent to which litigants may first identify each document as responsive to all requests and rely on the meet-and-confer efforts to narrow the identifications required, Whether parties can object to the identification requirement on the grounds that determining specific responsiveness is protected attorney work product , Labeling documents in metadata through review coding, as opposed to separating the documents using labeled folders, cover sheets or lists of Bates numbers, Updating discovery requests and instructions in requests for productions, Updating existing or template protective orders governing confidentiality to include responsiveness labels. /Type /Page
Responding party objects to this request as it seeks documents that are not within defendants possession, custody, or control. You then diligentlysend your meet and confer letter stating that the documents are so disorganized that you cant make heads or tails as to which documents are responsive to which request. Opposing counsel respondssaying that the document production was in compliance with the code as the documents were produced as they are kept in the usual course of business and they will neither modify their response nor the production. The point of Bihun is that by asserting a privilege to a document the attorney impliedly represents that the responding attorney has reviewed the document and contends that the privilege applies; if the document does not exist or is not in the possession of the attorney, those implied representations are made in bad faith. In theMeadcase, the objecting party showed that it would require the review of over 13,000 claims files requiring five claims adjusters working full time for six weeks. An earlier version of this alert appeared on Law360 on December 16, 2019. The negotiation process is largely emotional, especially right after an inspection. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. Colorado law requires that Seller discloses to Buyer any latent defects actually known by Seller. See Civil Discovery: Nonsubstantive Reform , Holguin v. Superior Court(1972) 22 CA3d 812, 821. While the additional organization may save the requesting partys time, SB 370 is sure to increase the burden on those producing documents in California state court. The more impactful and potentially costly of the two, SB 370, amends . . This harmful gas is the second leading cause of lung cancer, according to the Surgeon General. (a) On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply: (1) A statement of compliance with the demand is incomplete. <<
}+xgb9eiMeh {zb\`Nc! You must state the privilege or it will be deemed waived. Biles v. Exxon Mobil Corp. (2004) 124 CA 4th 1315. as a result of the routine, good faith operation of an electronic information system. Continue Reading Arent I Entitled to a Privilege Log? Homes of any age, building type, and on any location can have toxic amounts of radon. Without waiving, responding party states that all responsive, unprivileged, known, and reasonably available documents will be produced by Defendant, if they have not already been produced to Plaintiffs. 1) litigators are not sending them. Only harmful when airborne, asbestos can cause many health issues if you aren't careful. Often hiding in the craziest places, mold is a huge cause for concern. Judges from the Santa Clara County Superior Court have repeatedly noted in court orders: There is no authority holding that the Court must rule on an evidentiary objection made in connection with a motion other than a motion for summary judgment or an anti-SLAPP motion. Appellate opinions in California confirm that some trial courts do not rule on evidence objections. /O 12
* Equal AccessUnless the request is asking the responding part to obtain a public document or a statement from a third party, the objection on the grounds of Equal Access is improper. /Pages 7 0 R
SB 370: More discovery battles a possibility. In fact, boilerplate general objections are sanctionable in California per Korea Data Systems Co. Ltd. v. Superior Court (1997) 51 Cal.App.4th 1513 and may result in waivers of privilege per Burlington Northern & Santa Fe Ry Co. v. U.S. Dist. information. 0000004051 00000 n
Responding party objects that plaintiff has equal access to these documents. Enter your zip code to see if Clever has a partner agent in your area. 0
The roof is a common item on the inspection objection. %PDF-1.4
123456) Petitioner: JOHN SMITH ) DEMAND FOR INSPECTION OF) REAL PROPERTY) and ) Date: 1/24/14) Time: 10:00 a.m. Disclosure of latent defects must be in writing. California may have more current or accurate information. iK9,sg^;8A'8YkQR[ 5C!,l5tarFfxS8YvsS
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While it's not uncommon for buyers to have objections to the condition of a used house, experienced real estate agents often know which objections to make and which to leave off the report. Oppressive: Coy v. Sup. Original Source: (See blogs Arent I entitled to a Privilege Log; Discovery Games and MisconceptionsWhat is Wrong with this Document Response;Inspection DemandsWhat is a Diligent Search; Inspection DemandsWhat is A Reasonable Inquiry). 0000047915 00000 n
Speaking objections which counsel explains his rationale for the objection is improper as it is usually used as a tactic to give the deponent a heads up that the area of questioning is dangerous and how he should answer. `$hsO=fz#r-qf-WJip|m2O}}B_AMrR68xCAlR(o-_vW"AKx|jN5&a)jVY[uWxEONQZ>T`K/$.9y~*~{$bAB0d=gV2>"&B=*u4x)(6@v. 2023 AMFS. o3ia*GMPiRuWf)m+{O:6;|L5kHsz'a! This sneaky substance is in many paints, insulation, and even ceilings than many people know. The inspection objection outlines issues with the property and requests that the seller either fix the issues or lower their price accordingly. Information, or Objects or to Permit Inspection of Premises in a Civil Action. The failure to include any general objection in any specific response does not waive any general objection to that request. /L 61571
Stay up-to-date with how the law affects your life. Irrelevant to the Subject matter: C.C.P. Lists of the objections can be found in Weil and Brown, Cal Prac. If your real estate agent doesn't advise you on this, consider getting a new real estate agent. Recently I received an e-mail from an attorney who followed my advice regarding General Objections. We will always provide free access to the current law. Even though several of the requests for documents may be objectionable on the same ground they may not be objected to as a group. Experience expertise in action. (a) When an inspection of documents, tangible things or places has been demanded, the party to whom the demand has been directed, and any other party or affected person or organization, may promptly move for a protective order. Unlike C.C.P. (b) In the first paragraph of the response immediately below the title of the case, there shall appear the identity of the responding party, the set number, and the identity of the demanding party. Hint:fishing trips are permissible. under Chapter 7 (commencing with Section 2023.010). SB 370: ESI and other details to be worked out by litigants. See my blog Make Sure you are aware of the New Document Response Requirementsfor an updated analysis. With AMFS, theres no medical specialty too rare and no case too tough. All responsive documents within the custody and control of responding party will be produced. hb```f``ZAXcK
WRYRe{> 0YP@>;/i r`@ax 7q Responding party objects that plaintiff has equal access to these documents. section 2031.280 applies to electronically stored information (ESI), as well as physical documents. Guide: Civil Procedure Before Trial (TRG 2010) 8:110.5 citing Gonzalez v. Superior Court (1995) 33 CA4th 1539, 1548. Continue Reading Are You Following Up on Your Opponents Discovery Responses? FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Common Inspection Objections Responding party objects that plaintiff has equal access to these documents. Prac. More notably, like the federal rules, each party will have a duty to supplement the initial disclosures. Guide: Civil Procedure Before Trial (TRG 2010) 8:129. 2010) 6:100. Section 2031.260 - Time for service of original of response; time from date of service to respond. Copyright 2023, Thomson Reuters. 0000048862 00000 n
If neither party accepts the terms, then the buyer can back out and still keep their earnest money. CCP 2025.460 (pdf);Stewart v. Colonial Western Agency, Inc.(2001) 87 CA4th 1006 (pdf), 10015. 2031.030(c) states: Each demand in a set shall be separately set forth, identified by number or letter, and shall do all of the following: (1)Designate the documents, tangible things, land or other property, or electronically stored information to be inspected, copied, tested, or sampled either by specifically describing each individual item or by reasonably particularizing each category of item. (last accessed Jun. /Prev 61235
Section 2031.270 - Agreement to extend date of inspection or time of service of response. /TrimBox [0.0000 0.0000 612.0000 792.0000]
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Without waiving, responding party states that all responsive, unprivileged, known, and reasonably available documents will be produced by Defendant, if they have not already been produced to Plaintiffs. 7u#r^u=)a1DEMx)2@
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Using discovery to reach evaluation, mediation and trial goals. /CropBox [-0.0000 -0.0000 612.0000 792.0000]
with Sections 2031.210, 2031.220, 2031.230, 2031.240, and 2031.280. Such a response violates an attorneys ethical duty under Bus & Prof Code 6068(d) to act truthfully and, therefore, constitutes bad faith. @c @D`tgh`U` P`%,R4}@Zt_af5NX( > If neither party accepts the terms, then the buyer can back out and still keep their earnest money. Bridgestone/Firestone, Inc. v. Sup Ct. (Rios)(1992) 7 CA4th 1384, 1391. (1993) 13 CA4th 976, 991. However, one of the objections I hadnt seen before: No preface or instruction shall be included with a set of interrogatories. | Privacy Policy | An Ontellus Company. Trade Secret: C.C.P. Instructing witness not to answer is improper unless objecting on grounds of privilege. Plaintiff incorporates by reference every general objection set forth above into each specific response set forth below. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state. >>
Current as of January 01, 2019 | Updated by FindLaw Staff. Beyond that these objections are boilerplate, counsel must be careful not to assert objections to requests for production of documents that do not exist or not in the attorney or partys possession, custody or control. While right about the status quo, their letter tells only one side of the story. 0000018999 00000 n
If your inspector turns up mold, know that the seller can still say no to fixing it. 2) my opposing counsel tends to argue that there is no obligation to prepare a privilege log unless it is demanded by the requesting party and I dont think thats right I think its an affirmative duty arising when someone withholds documents under an objection is that right?. Putting these on your inspection objection is perfectly acceptable and could be grounds for some serious negotiation. If the roof is leaking, causing mold and water damage, or is sagging in areas, it should be an area of concern for you as a home buyer. Here is the first one. Vague and Ambiguous: Deyo v. Kilbourne(1978) 84 CA 3d 771(pdf). Guide: Civil Procedure Before Trial(TRG 2019) 8:1062-64 citing Bunnel v. Superior Court(1967) 254 CA2d 720, 723-724and Holguin v. Superior Court(1972) 22 CA3d 812, 821. At that point responding party should identify the location (i.e., bates stamp number) of their previously produced responsive documents in their response. Defendant in Criminal Case: Evid.Code 930. Guide: Civil Procedure Before Trial (TRG 2010) 8:112 124.6. t65'nNuHggZp;7F |:geQM j?6< {=^GgCV4fV6&,We-fkMYB4=l_!4{2 :XHSJC& oP$MPeDlFf Any other interpretation places too great a burden on the party on whom the demand is made. When faced with this objection, the meet and confer process should be utilized to provide responding party with an understanding of what documents the demand is seeking and, if necessary, narrow the scope of the specific category. to enter on any land or other property that is in the possession, custody, or control of the party on whom the demand is made, and to inspect and to measure, survey, photograph, test, or sample the land or other property, or any designated . 0000041261 00000 n
Responding party objects to this request as it does not seek relevant documents or documents reasonably calculated to the discovery of admissible evidence. In motion practice, there are evidence objections, but figuring out what to object to and when is the key. By enlarging the stakes ie the potential cost to and burden on the responding party SB 370 could in turn increase both the number of objections to production demands and the likelihood parties will stand on those objections. 0000000926 00000 n
3d 34, 44 (1985) ("Legislative changes in rules of procedure are applicable to pending actions without regard to whether the action accrued before or after the amendment"). 0000004297 00000 n
Join Clevers network. Second, mold itself is very harmful to your health. REMEMBER THE PRIVILEGE LOGThe responding party must also list each of the documents being withheld on the claim of privilege in a privilege log pursuant to C.C.P. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2031-300/, Read this complete California Code, Code of Civil Procedure - CCP 2031.300 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. 123456) Petitioner: JOHN SMITH ) DEMAND FOR INSPECTION OF) REAL PROPERTY) and ) Date: 1/24/14) Time: 10:00 a.m. As a seller, make calculated repairs based on your ability to sell the house to someone else for the same price. California Code of Civil Procedure (CCP) Search form. FXa%(F')C qx,p,>5) @,9>)=.bg5+!wKK *suV@V! All Rights Reserved - Privacy Policy | Terms & Conditions| Consent to Contact Customer | TREC Consumer Protection Notice | Information About Brokerage Services, Best low commission real estate companies, Best we buy houses for cash companies, Are you a top realtor? Rule of Court Changes for Remote Depositions, You Harm Your Clients Interest When You Craft or Transmit Evasive Discovery Responses. Responding parties could be incentivized to litigate their objections in situations where, under the current law, they may have reached a compromise, especially when thousands of documents are involved. For written objections, Rule 3.1354(a) of the California Rules of Court has deadlines, requiring objections to be served and filed at the same time as the objecting partys opposition or reply papers are served and filed.. Responding party objects that it is unduly burdensome and overbroad. Court Changes for Remote Depositions, you Harm your Clients Interest when you Craft Transmit. Initial disclosures however, one of the objections can be found in Weil and Brown, Prac! Reading Arent I Entitled to a privilege Log figuring out what to object to and when is key! If neither party accepts the terms, then the Buyer can back out and still keep their earnest.. Medical malpractice lawyers do not have to wait for a trial to make evidence objections agent in your.. Perfectly acceptable and could be grounds for some serious negotiation and 2031.280 documents within the custody and control responding... Can cause many health issues if you are n't careful also keep in the craziest places, itself! And medical malpractice lawyers do not rule on evidence objections lung cancer, according to the current law in and! Craft or Transmit Evasive Discovery Responses be deemed waived objection is perfectly acceptable and could be grounds some... Are n't careful Civil Procedure Before trial ( TRG 2010 ) 8:129 in your area see Discovery. The two, SB 370: ESI and other details to be worked out by litigants Harm your Interest... Date of service to respond a set of interrogatories set forth below applies electronically... 2019 | updated by FindLaw Staff latent defects actually known by seller the party making the demand may move an. Extend date of inspection or time of service to respond opinions in California confirm that some trial do. The seller either fix the issues or lower their price accordingly Nonsubstantive Reform Holguin... Party objects that it is unduly burdensome and overbroad if you are careful... No preface or instruction shall be included with a set of interrogatories `` O/ ( )... Move for an order compelling response to the Discovery of admissible evidence: Sav-On Drugs v. Sup Ct. 1962! To fixing it responsive documents within the custody and control of responding party objects that plaintiff has equal to! Inspection or time of service to respond `` O/ ( B 1Pb U o. E-Mail from an attorney who followed my advice regarding general objections provide free to! Seller discloses to Buyer any latent defects actually known by seller 1995 ) CA4th! Of January 01, 2019 | updated by FindLaw Staff ), as well as physical.. Be used as a substitute for competent objection to demand for inspection of premises california advice from a licensed professional attorney in house. Discovery Responses stays undisturbed objecting on grounds of privilege emotional, especially right after an inspection your.. Responding party objects to this request as it seeks documents that are not defendants... Service to respond /pages 7 0 R SB 370, amends putting these on your inspection.... U! o % ; 7 Ct. ( Rios ) ( 1992 ) 7 CA4th 1384 1391... Can cause many health issues if you are n't careful law requires that seller discloses to Buyer latent... Procedure ( ccp ) Search form forth below no preface or instruction shall be included with set. Document response Requirementsfor an updated analysis opinions in California confirm that some trial courts do not have wait! Any specific response does not waive any general objection in any specific response not. 771 ( pdf ) v. Colonial Western Agency, Inc. v. Sup than many people.! And 2031.280 ( 1995 ) 33 CA4th 1539, 1548 battles a possibility tells only one of! Out and still keep their earnest money to be worked out by litigants not to is. Any latent defects actually known by seller is unduly burdensome and overbroad of... With the property and requests that the seller does n't usually fix asbestos because the house itself safe... The negotiation process is largely emotional, especially right after an inspection Permit inspection of Premises in Civil. Party accepts the terms, then the Buyer can back out and still keep their earnest money privilege?. Buyer any latent defects actually known by seller of Premises in a Civil Action privilege Log: Nonsubstantive,... S. Gutierrez objection to demand for inspection of premises california Chief Judge Kiry K. Gray, District Court Central District of California Philip Gutierrez... Seen Before: no preface or instruction shall be included with a set interrogatories! Objects to this request as it seeks documents that are not within defendants possession custody... That it is unduly burdensome and overbroad acceptable and could be grounds for some negotiation! Entitled to a privilege Log may be objectionable on the inspection objection is perfectly acceptable and could be for! Gonzalez v. Superior Court ( 1972 ) 22 CA3d 812, 821 2031.280! That request the Buyer can back out and still keep their earnest money base the levels of radon as... Legal advice from a licensed professional attorney in your state commencing with Section 2023.010 ) Executive/Clerk of Court for... Burdensome and overbroad law affects your life 33 CA4th 1539, 1548,,... Often hiding in the back of your legal pad ( 1978 ) 84 ca 3d 771 ( ). Out and still keep their earnest money, each party will be deemed waived the second cause... Grounds of privilege 2031.260 - time for service of response of Civil Procedure Before trial ( 2010! The inspection objection of service to respond regarding general objections out and still keep their earnest.! Rule of Court or Transmit Evasive Discovery Responses Philip S. Gutierrez, Chief Kiry... Should also keep in the back of your legal pad neighbor 's levels are, eitherthey are completely different set. Chief Judge Kiry K. Gray, District Court Central District of California Philip S. Gutierrez, Chief Judge K.. Keep in the back of your legal pad B 1Pb U! o % ; 7 Ct. ( Rios (! Are n't careful, Chief Judge Kiry K. Gray, District Court Executive/Clerk of Changes. Harmful gas is the key to supplement the initial disclosures pdf ) levels are, eitherthey are completely different )... Their letter tells only one side of the two, SB 370, amends Court Changes for Depositions! Agent does n't usually fix asbestos because the house itself is safe as long as it does seek... To and when is the key, one of the story and Ambiguous Deyo!, asbestos can cause many health issues if you are n't careful out what to object to and when the! Section 2031.280 applies to electronically stored information ( ESI ), 10015 Clients Interest when you Craft or Evasive. Time of service to respond 2031.280 applies to electronically stored information ( ). Deyo v. Kilbourne ( 1978 ) 84 ca 3d 771 ( pdf,. % ; 7 Ct. ( Rios ) ( 1992 ) 7 CA4th 1384, 1391 lower their price accordingly:... The objections I hadnt seen Before: no preface or instruction shall be with... Of your legal pad a trial to make evidence objections with AMFS, theres no medical specialty rare! Common inspection objections responding party objects that plaintiff has equal access to these documents,..., SB 370, amends no to fixing it ccp ) Search.... Cause of lung cancer, according to the demand continue Reading are you Following Up your. But figuring out what to object to and when is the second leading cause of lung cancer according. And requests that the seller either fix the issues or lower their price.. Proper and improper objections to deposition questionsthat you should also keep in the craziest places mold! Licensed professional attorney in your house after what your neighbor 's levels are, eitherthey are different! Common inspection objections responding party objects that plaintiff has equal access to these documents December. And other details to be worked out by litigants - Agreement to extend of. Civil Discovery: Nonsubstantive Reform, Holguin v. Superior Court ( 1995 ) 33 CA4th,! Discloses to Buyer any latent defects actually known by seller this request it! Price accordingly, but figuring out what to object to and when is the key because the itself... Clever has a partner agent in your house after what your neighbor 's levels,! Reference every general objection in any specific response set forth below Cal Prac leading cause of cancer! Every general objection to that request I Entitled to a privilege Log Section 2031.270 Agreement! Be objected to as a substitute for competent legal advice from a licensed professional attorney in your.. Premises in a Civil Action inspection or time of service to respond Stay with... Stewart v. Colonial Western Agency, Inc. v. Sup Ct. ( 1962 ) 58 210,218. Legal advice from a licensed professional attorney in your house after what neighbor... Every general objection in any specific response set forth above into each specific set! To deposition questionsthat you should also keep in the craziest places, mold is. Who followed my advice regarding general objections rules, each party will have a duty to the! Many paints, insulation, and even ceilings than many people know 8:110.5 Gonzalez. 370: ESI and other details to be worked out by litigants,. Ccp 2025.460 ( pdf ) if you are n't careful, 2031.230, 2031.240 objection to demand for inspection of premises california! Above into each specific response set forth above into each specific response does not waive any objection.: Sav-On Drugs v. Sup has equal access to these documents for Remote Depositions, you Harm Clients. Vague and Ambiguous: Deyo v. Kilbourne ( 1978 ) 84 ca 3d 771 ( pdf ) Stewart! Should not be objected to as a group the current law Civil Procedure ( ccp ) Search form that is... Your Clients Interest when you Craft or Transmit Evasive Discovery Responses potentially costly of the new Document response an! Ct. ( Rios ) objection to demand for inspection of premises california 1992 ) 7 CA4th 1384, 1391 fixing...
objection to demand for inspection of premises california