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Discovery limit in Cali?


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Hi,

I am being sued by Midouchbagland Funding LLC in California, and I sent them Interrogatories, Request for Production of Documents, and Request for Admissions of my own. They sent me a letter back saying that I exceeded the limit of questions and that they won't be responding to it. Am I missing something because I looked up the amount of questions/requests I can send in CCP and I thought it was 35 or less special interrogatories, request for admissions, and production of docs? or did I interpret that wrong and it actually means 35 TOTAL? I sent them 20 Interrog questions, 17 requests for admissions and 17 request for production of docs. Ugh, I feel so stupid right now:?

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It has been awhile since I reviewed it but I think 35 total is correct. You may want to send Bill of Particulars, CCP 454. As long as the complaint is not soleyl based on " Account Stated" they will need to send you itemization of the account.

You can search the site for threads on Bill of Particulars, there are several really good threads...

This may help you get some of the docs you requested in your discovery request. Fire this off early next week send CMRR, then re-work your discovery requests down to the proper number. Many times it is good to use only 20 for your first request. Then you have another 15 if needed, on a second request for discovery.

I must say, that discovery usually doesn't lead to much other than a headache, as most CA's will not give much information. So you really need to be prepared to Motion the Court for help and sancations.

Good Luck

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Thank you so much! I will look into Bill of Particulars and I am going to meet with someone Monday morning to help me out with revising my Interrogatories, etc. so we can get this going. I'm expecting the worst but I don't actually believe I owe anything and these guys have not given me any shred of proof that I do, so I will begin to prepare Motion to Compel to be one step ahead, just in case.

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