Can You Request Discovery in Chunks?

[mommamia3]

I know in CA you can only submit 35 discovery requests to Plaintiff. My question is can I do it in chunks? Can I send five pod requests and five admissions requests and then later send five more of each for example as long as all together I never go over 35?

Thanks in advance.

[calawyer]

Originally Posted by mommamia3

I know in CA you can only submit 35 discovery requests to Plaintiff. My question is can I do it in chunks? Can I send five pod requests and five admissions requests and then later send five more of each for example as long as all together I never go over 35?

Thanks in advance.

Yes. And it is the better practice to do so. Makes it much easier to file a motion to compel if necessary and makes the Judge happier to decide the motion. Besides, sometimes you want to do "follow up" discovery on what you have been given.

[mommamia3]

I was hoping I had that right. Thanks!

[Rivertime]

For what it's worth... I too appreciate the answer Calawyer... Thanks!

[helpme]

Originally Posted by mommamia3

I was hoping I had that right. Thanks!

Mommamia3,

This will help you too if all they respond with is Objections and Privilege. You will not have to do a lot of typing if you only send 5 pod requests. Believe me it took me at least a week to gather my thoughts and use statutes and case laws to respond to their objections and of course with calawyer's help when I got stuck.

[usagi555]

If I had my case to do over again, I would have sent requests for the most damning possible evidence ASAP, then started asking for the other stuff that I did want them to provide later. My reasoning is to immediately start the clock ticking for them with providing the evidence while keeping it much cleaner with regards to what is getting a motion to compel vs what is getting a motion to preclude.