mommamia3 Posted February 22, 2012 Report Share Posted February 22, 2012 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. Link to comment Share on other sites More sharing options...
calawyer Posted February 22, 2012 Report Share Posted February 22, 2012 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. Link to comment Share on other sites More sharing options...
mommamia3 Posted February 22, 2012 Author Report Share Posted February 22, 2012 I was hoping I had that right. Thanks! Link to comment Share on other sites More sharing options...
Rivertime Posted February 22, 2012 Report Share Posted February 22, 2012 For what it's worth... I too appreciate the answer Calawyer... Thanks! Link to comment Share on other sites More sharing options...
helpme Posted February 22, 2012 Report Share Posted February 22, 2012 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. Link to comment Share on other sites More sharing options...
usagi555 Posted February 22, 2012 Report Share Posted February 22, 2012 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. Link to comment Share on other sites More sharing options...
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