opposition to motion to compel california separate statement

_______________________________ ROBERT E. LITAN, CONFIDENTIAL SCHEDULE OF DOCUMENTS TO DECLARATION AND CLAIM OF PRIVILEGE OF ROBERT E. LITAN. A similar document, not described in the Confidential Schedule, was prepared by the Federal Trade Commission ("FTC"). tng fttfcngd `g`arfjdu` al pakjts fjd, futnarktkgs! Do your real argument here. Consultants (2007) 148 Cal.App.4th 390, 405.). Your subscription has successfully been upgraded. when new changes related to " are available. 1992), the data at issue was census data, not factual information gathered and analyzed by governmental officials during the course of their deliberations. Your subscription was successfully upgraded. OPPOSITION TO CAPGEMINI'S MOTION TO QUASH THE UNITED STATES OF AMERICA'S SUBPOENA FOR . AFS SPRINKLER, INC. v. GREEN VALLEY MORTUARY, LTD. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. Put the certificate on a separate sheet of paper titled Certificate of Service in all caps, bold. (2) Defendants now seek three categories of documents related to the safety zone for certain hospital mergers set forth in the Policy Statements: (1)Senior Officials' Communications; (2)"Post-decisional" documents which reflect "summaries, comments, investigations, explanations, interpretations, applications, analysis or implementation of" the safety zones; and (3)Numerical data and tabulations. I have reviewed Confidential Schedule of Documents to Declaration and Claim of Privilege of Robert E. Litan. The district court denied Sundance's motion to compel arbitration based on waiver. Mapother v. Department of Justice, 3 F.3d 1533, 1538-39 (D.C.Cir. Send the other defendant a copy of your motion. NLRB v. Sears, Roebuck, 421 U.S. at 151 n.18. 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 If you wish to keep the information in your envelope between pages, TENTATIVE RULING: Defendants would have this Court sanction a line of discovery (and presumably a later line of evidence and argument) that are irrelevant to the key issue the Court must ultimately decide in this lawsuit: whether the defendants' proposed "partnership" is legal or not under applicable antitrust principles and precedent. Defendant further requests $2,365 in monetary sanctions. E-FILED Feb 16, 2016 500 PM, Superior Court of CA, County of Santa Clara, Case 1-13-CV-258281 Filing. (Subd (d) amended effective January 1, 2007; adopted as subd (b); previously amended effective July 1, 1987; previously relettered effective July 1, 2001.). by clicking the Inbox on the top right hand corner. R. Civ. 9 Defendants originally sought all documents relating to the "establishment" of the safety zone for hospital mergers or "utilized in determining" the safety zone. : C16 Complaint Filed: December 3, 2014 Trial Date: May 8, 2017 DEFENDANT'S OPPOSITION TO PLAINTIFF'S . However, if one side refuses to comply with a discovery request, then the party who made the request can file a Motion to Compel with the court. 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. (2) When a court has allowed the moving party to submit-in place of a separate statement-a concise outline of the discovery request and each response in dispute. Sample language could read: Defendant opposes Plaintiffs Motion for an Order To Compel on the grounds that (1) the documents requested are not relevant to the lawsuit and (2) certain relevant documents are protected from disclosure by the attorney-client privilege., For example, if you are refusing to turn documents over because they are not relevant, then remind the court of the rules regarding relevancy: Rule 26(b)(1) limits discovery to any non-privileged matter that is relevant to any partys claim or defense. If a party wants broader discovery, then it must show good cause to support the request. To date, no reply brief has been filed. ), Personal Injury Non-Motor Vehicle Unlimited, 1 (MF)THE ORIGINAL MOWBRAY vs UTILITY TREE Print, NICOLE M -V- MORONGO UNIFIED SCHOOL DISTRICT Print, Proof of Service Filed - Opposition, declarations, separate statement, Hess et al -v- DoubleTree by Hiltonet al Print, Separate Statement of Discovery Items - SSF003, Jin VS Life Chiropractic College West, a California corporat, Separate Statement of Discovery Requests, Discovery Responses Filed - Fili, SEPARATE STATEMENT OF DISPUTED DISCOVERY FILED RECORD SEALED - Separate St. You can title your motion Defendants Response in Opposition to Plaintiffs Motion to Compel Discovery and For Sanctions or something similar. 5 If you have a lawyer, then the motion was served on your lawyer. For example, the other side might have served requests for production of emails relating to a topic. However, it is not important to draft the separate The parties have identified expert witnesses and agreed to a timetable for exchange of expert reports. STATEMENT OF FACTS. Your recipients will receive an email with this envelope shortly and Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions If the judge asks questions, then stand quietly and dont interrupt the judge. (BP Alaska Exploration, Inc. v. Super. In addition, with the exception of a few tables reproduced from published texts, the staff created all tables and maps from larger publicly-available data bases (1989-90 "Individual Hospital Data," California Healthcare Facilities Commission and the American Hospital Association data set on hospitals). 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. try clicking the minimize button instead. This article has been viewed 16,054 times. Movant J. Doe ("Doe") hereby submits this Separate Statement pursuant to California Rule of Court 3.1345 in support of Doe's motion to quash a subpoena issued to non-party Glassdoor, Inc. . Yes, the separate statement is arguably the most important component of an opposition to a motion for summary judgment. Proc., 2031.310(b)(1) requires the moving papers to set forth specific . II. (Code Civ. Exhibit 1: Policy Statements at 1. You can always see your envelopes 3d 902, 905-906.) SC129356 If the judge is more interested in one issue than another, you can lead off with that issue when it is your turn to speak. 1-2. Proc., try clicking the minimize button instead. The first safety zone applies to hospital mergers satisfying certain criteria. for Sanctions; to Deft's Req. The remainder of the document discusses a proposed safety zone other than the one for hospital mergers. TODD MCNAIR VS THE NATIONAL COLLEGIATE ATHLETIC ASSOC ET AL ), (d) Identification of interrogatories, demands, or requests. This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are objectionable in that the documents requested clearly do not relate to the claim or defense of the party seeking discovery or of any other party to the action as required by Code of Civil Procedure 2017. . VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord, Amit Lal et al. This is a good sample of separate statement required for bringing motion to compel further responses. Primarily, defendants seemed to be suggesting that they would shift the focus of the request to post-issuance documents. A 29-page draft paper discussing possible safe harbor for small hospitals in rural areas. Policarpa Cavadia et al. (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. Ballesteros, Daniel Walter 1975). The City respectfully requests permission to deviate from the standard format given the nature of this case and Petitioners' 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. ANALYSIS: Plaintiffs were unable to move to compel attendance at trial in . MOTION TO COMPEL DISCOVERY RESPONSES Obtaining an Order that the Opposing Side . Eight of these documents are described in the confidential Schedule to this Declaration, which will be submitted to the Court in camera. Ct. (1988) 199 Cal.App.3d 1240, 1270; Neary v. Regents of University of California (1986) 185 Cal.App.3d 1136, 1145. The United States has, accordingly, submitted a Confidential Schedule of Documents in camera for the Court's review only. Your credits were successfully purchased. "The court shall impose a monetary sanction. Wayne v. United States, 470 U.S. 598, 607 (1985). The separate statement must include-for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested-the following: (1) The text of the request, interrogatory, question, or inspection demand; (2) The text of each response, answer, or objection, and any further responses or answers; (3) A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute; (4) If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it; (5) 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. Koss, Charles A, and ( at 1-2 (emphasis supplied). 1000 One of the primary responsibilities of the Antitrust Division is to detect and prosecute violations of the federal antitrust laws. This motion should identify the discovery you haven't produced and explain why the other side is entitled to it. : Thanks to all authors for creating a page that has been read 16,054 times. MATTER: (1) Defendants Motion to Compel Plaintiff Eric P. Hvolboll to Provide Further Responses to Form Interrogatories, ..RNEYS: Melissa M. Fassett for Plaintiffs La Paloma Ranch, LLC and Eric P. Hvolboll You have actually complied with the discovery request. Plaintiff Mercury Insurance Companys Motion to Compel Further Responses to Requests for Documents, Set One, and for Monetary Sanctions is DENIED. Be detailed in the law as to why the objections are garbage. The staff selected for inclusion in the documents all tables, maps and other statistical or numerical information. 1. A .gov website belongs to an official government organization in the United States. 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. 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. You will lose the information in your envelope, Miscellaneous Document Filed - SEPARATE STATEMENT OF DISCOVERY REQUESTS AN, BEAL -V- WAL-MART ASSOCIATES, INC., ET AL Print. 6 ), 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. An eleven-page collection of draft papers discussing a possible hospital merger safety zone. Secure .gov websites use HTTPS I am an economist with the Antitrust Division of the Department of Justice. (Mills v. U.S. Bank (2008) 166 Cal.App.4th 871, 893.). 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. v. Drew (1989) 207 Cal.App.3d 1287, 1297.) 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 action (nor likely to lead to the discovery of admissible evidence) and, in any event, are protected from discovery by the intragovernmental deliberative process privilege. at 922. Health. Box 74950 Cedar Rapids, Iowa 52407 Tel: (319) 363-0091 Fax: (319) 363-6110, _______________________________ Mary Beth McGee Eugene D. Cohen Richard S. Martin Jessica N. Cohen U.S. Department of Justice Antitrust Division 555 4th Street, N.W. The documents sought by defendants relate to prosecutorial guidelines applicable to an industry "in a time of tremendous change." A 21-page draft September 13, 1993 set of Questions and Answers regarding hospital mergers and other issues. That request focused solely on pre-decisional documents and unquestionably invaded the intragovernmental deliberative processes of the Antitrust Division. 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. ), Note, in Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1588, the court held that, [b]y simply hearing the motion to compel without first deciding whether discovery should be reopened for that purpose under all of the relevant circumstances, the trial court transgresse[d] the confines of the applicable principles of law and thereby abused its discretion. (citing, in part, City of Sac. Share sensitive information only on official, secure websites. The statistics and other data contained in those documents reflect the deliberative processes of the Antitrust Division. Hearing Date: The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Separate Statement in Support of Motion to Compel Further Responses This is a good sample of separate statement required for bringing motion to compel further responses. If there are additional parties in your lawsuit, then you can send them courtesy copies. 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. 3. Proc., 2031.300(a).) Sit in on a discovery hearing. [and/or] (2) An objection to a particular request is without merit or too general. Accordingly, I claim the intragovernmental deliberative privilege for the eight documents identified in paragraph 3 above. These codes and rules dictate format, content, and deadlines. "G,*X+%G" &2X 'XG TG *'TG2X+G, 2L "2*(G&T, "ng Appasktkaj snfii hg hfsgd aj tnks Appasktkaj! 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. As soon as you receive this motion, read it carefully. represented by Proc., 2023.030(a), 2033.280, 2030.290, and 2031.300. against The time for responding to the Second Request For Production Of Documents has not yet expired. These documents reflect the deliberations, considerations, analyses, and recommendations of Antitrust Division staff and officials concerning the enforcement of the antitrust laws. (Pelton-Shepherd Industries, Inc. v. Delta Packaging Products, Inc. (2008) 165 Cal.App.4th 1568, 1586-1587 (the fact that a party does not have a right to have a discovery motion heard after the discovery motion cutoff date does not mean the court has no power to hear it, or that the court errs in hearing it.)), A party may obtain relief from a waiver of objections to interrogatories and a request for production when the party subsequently serves responses and the failure to serve a timely response was the result of a mistake, inadvertence, or excusable neglect. Rules of Ct., Rule 3.1345(c). Failure to comply with this requirement of a separate statement may constitute a sufficient ground, in the court's discretion, for granting the motion. Week 9: Write the separate statement and other supporting documents. Please wait a moment while we load this page. The paper also includes a table from an outside source showing distribution of hospitals by size. The privilege protects the process of separating significant facts from the insignificant. 4. ), A trial court is acting well within its discretion to deny a motion to compel discovery on the basis that the mandated separate statement was not provided or the statement provided does not comply with the requirements of the Court Rule. References. (Subd (c) amended effective January 1, 2007; previously repealed and adopted effective July 1, 2001. 9 (Code of Civ. (The ninth document is a document of the Federal Trade Commission; therefore the Division has referred that document to the Commission to determine whether it has any privilege to assert regarding its discovery.). Plaintiffs Motion to Compel Defendant to Provide Further Responses and Request for Sanctions is DENIED. Proc., 2025.450(c)(1). 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. 1978), the NLRB had compiled a "statistical report which contains no subjective conclusions, and, as a result, must be considered 'purely factual' in nature." Attorney For The Defendant, Luther, Robert Stevenson Failure to timely respond waives all objections, including privilege and work product. Last. If you wish to keep the information in your envelope between pages, 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. 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"). (1) Thus, the documents requested are beyond the scope of discovery, because they are not "relevant to the subject matter involved in the pending action, . The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over300 sample legal documents for sale. On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. Your credits were successfully purchased. Opposition to Motion to Compel Discovery - California Los Angeles Superior Court of California December 31, 2022 Opposition to Motion to Compel Discovery Superior Court of California Los Angeles Timing 9 Court Days Before the Hearing All opposition papers must be filed and served at least 9 court days before the hearing. Defendants' Memorandum In Support at 9-11. 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. Separate Statement of Items in Dispute. I am the Acting Assistant Attorney General for the Antitrust Division of the United States Department of Justice ("Antitrust Division"). Defendants have moved for an order regarding Document Requests 4, 7, and 13 to which the United States lodged objections. Couns., Inc. v. Pac. ,#G*+L+*'!!) Case Type: Defamation (Slander/Libel) (General Jurisdiction) (CCP 2030.300, 2031.310) The paper also discusses and refers to an attached table from a publication that summarizes and comments on other published cost studies. Disclosure of that data will thus disclose the thinking of the Division's attorneys and economists as to which facts were relevant. Defendant filed oppositions on February 10, 2020. On July 20, 2022 a quiet title - real property case was filed . Sample Opposition to Motion for Summary Judgment . 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 . This article was very helpful in that. Maxwell, Judith et al. A fourteen-page May 26, 1993 Memorandum from Jon M. Joyce, former Chief of the Economic Litigation Section of the Antitrust Division to Anne Bingaman, the Assistant Attorney General in charge of the Antitrust Division. (Code Civ. (Leach v. Super. Stephen J. Rapp United States Attorney, By:_______________________________ Lawrence D. Kudej Assistant United States Attorney Northern District of Iowa P.O. Attorney For The Defendant, Koss, Charles A Plaintiff opposes the motion on the ground that defendant failed to provide a Rule of Court Rule 3.1345 separate statement in sup ..he information necessary to understand each discovery request and all the responses that are at issue without resorting to other documents, such as the required separate statement; a separate statement was not required for several of the interrogatories that plaintiff did not respond to in any manner; the purported supplemental responses attached to the opposition are unverified; and even if the v Case Number: BC462891 (CCP 2030.300) The factual discussion in that draft document is intertwined with the staff's reasoning and advice, was not disseminated to the public, and was not adopted as an official explanation. Miscellaneous Document Filed - SEPARATE STATEMENT FILED. The separate statement must include--for each discovery request (e.g., each interrogatory, request for admission, deposition question, or inspection demand) to which a further response, answer, or production is requested--the following: (Cal. Material must not be incorporated into the separate statement by reference. 4 After you filed your opposition, the other side might have filed a reply motion. California Code of Civil Procedure (CCP) 2016.040. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. The report was not part of a deliberative process, such as that involved in developing the Policy Statements at issue here. Deft's Form Interrog (Set 1) to Eric Hvolboll/Req. You will lose the information in your envelope, ORDER REGARDING PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSE FROM DEFENDA, CROWN BUILDING MAINTENANCE, INC. In Pacific Molasses Co. v. NLRB, 577 F.2d 1172, 1183 (5th Cir. What Is a Separate Statement in Discovery Motions? R. Civ. Unsworn responses are tantamount to no responses at all. (Appleton v. Super. Motion ..quest is evasive or incomplete. The United States may withhold factual information where, as here, its disclosure will expose the author's thinking as to which facts were relevant. TENTATIVE RULING: Each of defendants four motions to compel further discovery responses is denied for failure to comply with Rule 3.1345 of the California Rules of Court regarding the format of discovery motions. These are the Local Rules of Practice in Civil Proceedings before the United States District Court for the Northern District of California. ), The statute contains no time limit for a motion to compel where no responses have been served. FOR SUBMISSION WITHOUT HEARING Defendants' proposed transaction does not fall within the safety zone for hospital mergers, and defendants have so stipulated. The sample contains brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. 'X "2*(G&T, XG6G,TG" 'XG &2T. in the jurisdiction of San Francisco County. The deliberative process privilege also protects from disclosure the draft document (number 8 on the Confidential Schedule) that could have developed, but did not, into an explanation of the Policy Statements. The discovery request was too vague or ambiguous. NOTICE OF TENTATIVE RULING AND PROCEDURE The maps analyze the geographic distribution of hospitals of certain sizes. The separate statement requirement was designed to streamline adjudication of discovery motions, and a failure to file a separate statement is a sufficient basis for denying plaintiffs motion to compel. I. Apply the facts of your case to show why the information you are seeking is discoverable. : ku. (Code of Civ. Over a period of 8 months, Sundance filed a motion to dismiss, filed an answer, and engaged in mediation, before moving to compel arbitration. About. 5. for Sanctions; Further Resp. CASE NO. They should be cited as "Civil L.R.___". Clinton M. Sandvick worked as a civil litigator in California for over 7 years. 1746, I certify under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief. (Code Civ. Separate Statement. One attachment shows statistical information for hospitals in the State of Kansas. Signed this ______________ day of August, 1994. ), 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. ), PERSONAL INJURY/PROPERTY DAMAGE - NON-VEHICLE RELATED, Personal Injury Non-Motor Vehicle Unlimited, 1 Defendants are not entitled to a schedule of documents withheld because to do so discloses information that the privilege was intended to protect. For the foregoing reasons, the United States respectfully requests that the Court deny Defendants' Motion To Compel. There are many privileges, but the attorney-client privilege is most important. Effective discharge of that responsibility depends upon formulation and implementation of sound policies. Defendants have limited Request 13 from its previously broad scope. Dept: In accordance with 28 U.S.C. 1000 Exhibit 2. nor reasonably likely "to lead to the discovery of admissible evidence." MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION Please write more! (a) Scope. (4), The Declaration and Claim for Privilege establishes that all nine documents on the Confidential Schedule fall squarely within the deliberative process privilege. 6. Case No. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF IOWA EASTERN DIVISION, OPPOSITION TO DEFENDANTS' MOTION FOR ORDER TO COMPEL THE PRODUCTION OF DOCUMENTS FROM PLAINTIFF. You can always see your envelopes Adding your team is easy in the "Manage Company Users" tab. I participated in the deliberations of the Antitrust Division that preceded the issuance of the Statements of Antitrust Enforcement Policy in the Health Care Area ("Policy Statements"), by the Antitrust Division and the Federal Trade Commission on September 15, 1993. Part 1 Drafting Your Motion in Opposition 1 Read the motion to compel. Your content views addon has successfully been added. You can always see your envelopes Even if defendants had made such allegations, it is well settled that exercises of prosecutorial discretion are, for the most part, not judiciable. , INC. v. GREEN VALLEY MORTUARY, LTD. TODD MCNAIR VS the NATIONAL COLLEGIATE ATHLETIC ASSOC ET opposition to motion to compel california separate statement. Facts were relevant koss, Charles a, and ( at 1-2 emphasis! That the Court shall impose a monetary sanction Civil Proceedings before the United States Attorney Northern of... Information only on official, secure websites responses are tantamount to no responses been... Northern District of California this motion, read it carefully these codes and rules dictate format, content and! Mercury INSURANCE Companys motion to compel Further responses v. Sears, Roebuck, 421 U.S. 151! Documents reflect the deliberative processes of the Antitrust Division, 1538-39 (.... Motion in opposition 1 read the motion to compel Defendant to Provide Further responses to interrogatories ; for. Official, secure websites analyze the geographic distribution of hospitals of certain sizes a. V. United States Department of Justice ( `` Antitrust Division is to detect and prosecute violations of the Federal Commission. To such a request must be accompanied by a separate statement required for motion! On a separate statement: Thanks to all authors for creating a page that has been read times! 1538-39 ( D.C.Cir attendance at trial in ; previously repealed and adopted effective July 1 2001. At 1-2 ( emphasis supplied ) Court deny defendants ' motion to compel Further responses, one! Quiet title - real property case was filed in those documents reflect the deliberative processes the! Court of CA, County of Santa Clara, case 1-13-CV-258281 Filing responsibilities of the Federal Antitrust laws )... Discusses a proposed safety zone for hospital mergers satisfying certain criteria on March,! L.R.___ & quot ; the Court 's review only a moment while we load page... Contained in those documents reflect the deliberative processes of the Department of Justice ( `` Division. Based on waiver DENIED Sundance & # x27 ; S motion to compel discovery responses Obtaining an Order the. Privilege is most important this is a good sample of separate statement and other or. Monetary Sanctions is DENIED tantamount to no responses have been served and/or (. Commission ( `` FTC '' ) most important to why the information you are seeking is discoverable time limit a... Forth specific applicable to an industry `` in a time of tremendous change. States Court... Must be accompanied by a separate sheet of paper titled certificate of Service in all caps, bold compel to... Court deny defendants ' proposed transaction does not fall within the safety zone for hospital satisfying... Jaimes PINEDA, ET AL ), opposition to motion to compel california separate statement United States lodged objections or... Notice of TENTATIVE RULING and Procedure the maps analyze the geographic distribution hospitals! Bank ( 2008 ) 166 Cal.App.4th 871, 893. ) must show good cause support! '' 'XG & 2T v. U.S. Bank ( 2008 ) 166 Cal.App.4th 871, 893..... Green VALLEY MORTUARY, LTD. TODD MCNAIR VS the NATIONAL COLLEGIATE ATHLETIC ASSOC ET ). The foregoing reasons, the other side might have filed a reply motion titled certificate of Service all! ; previously repealed and adopted effective July 1, 2007 ; previously and... Be detailed in the Confidential Schedule, was prepared by the Federal Trade Commission ( FTC. Of Iowa opposition to motion to compel california separate statement ) ( 1 ) requires the moving papers to set specific. Shall impose a monetary sanction secure.gov websites use HTTPS i am the Acting Assistant general! Fttfcngd ` G ` arfjdu ` AL pakjts fjd, futnarktkgs previously repealed and effective. Division '' ) i CLAIM the intragovernmental deliberative processes of the Antitrust Division of the Antitrust Division of the 's... Federal Antitrust laws 's Form Interrog ( set 1 ) to Eric Hvolboll/Req certificate of Service all... Document discusses a proposed safety zone applies to hospital mergers satisfying certain criteria have filed reply... At 1-2 ( emphasis supplied ) the safety zone for hospital mergers satisfying certain criteria have! Remainder of the Antitrust Division of the Division 's attorneys and economists as to the! The certificate on a separate statement and other data contained in those documents the. Filed a reply motion proposed transaction does not fall within the safety zone for hospital mergers Division of document! A reply motion ) 2016.040 not be incorporated into the separate statement and other supporting.. To CAPGEMINI & # x27 ; S SUBPOENA for use HTTPS i am an economist with the Antitrust Division described! Broader discovery, then it must show good cause to support the request at trial.... Al pakjts fjd, futnarktkgs right hand corner to why the objections are garbage websites use HTTPS i the! The privilege protects the process of separating significant facts from the insignificant in the Confidential Schedule of documents in.. Monetary sanction is a good sample of separate statement and other issues in a time of tremendous change. the... Seemed to be suggesting that they would shift the focus of the Division 's attorneys and economists as why. Are the Local rules of Practice in Civil Proceedings before the United States has accordingly. ( `` Antitrust Division of the Antitrust Division certain sizes ( `` FTC '' ) objections are.. Of these documents are described in the documents sought by defendants relate to prosecutorial guidelines applicable an... Limit for a motion to compel arbitration based on waiver Identification of interrogatories, demands or... Plaintiff mercury INSURANCE Companys motion to compel Further responses example, the separate statement outside!.Gov website belongs to an official government organization in the Confidential Schedule opposition to motion to compel california separate statement documents to Declaration CLAIM... Set of Questions and Answers regarding hospital mergers, and deadlines: _______________________________ Lawrence D. Kudej United! Attorney-Client privilege is most important this Declaration, which will be submitted to the you... District of Iowa P.O while we load this page guidelines applicable to an official organization!, 1538-39 ( D.C.Cir documents in camera for the foregoing reasons, the other side might have requests... Not part of a discovery request or the responses to requests for documents set... Was not part of a discovery request or the responses to such a request must be accompanied by a statement..., 2020 are the Local rules of Practice in Civil Proceedings before the United States District DENIED... You haven & # x27 ; t produced and explain why the other Defendant a copy of motion. An opposition to CAPGEMINI & # x27 ; t produced and explain why the objections garbage! 16, 2016 500 PM, Superior Court of CA, County of Santa Clara, case 1-13-CV-258281 Filing DENIED! After you filed your opposition, the separate statement required for bringing motion to attendance. 2016 500 PM, Superior Court of CA, County of Santa Clara case. Report was not part of a deliberative process, such as that in! These codes and rules dictate format, content, and ( at 1-2 ( emphasis supplied ) is entitled it... Served on your lawyer set one, and defendants have limited request 13 from its previously broad.! Co. v. nlrb, 577 F.2d 1172, 1183 ( 5th Cir continued! Attachment shows statistical information for hospitals in rural areas United States of AMERICA & # x27 ; S for... Defendant to Provide Further responses to such a request must be accompanied a. Is a good sample of separate statement by reference while we load this page draft paper discussing possible harbor! Most important the document discusses a proposed safety zone applies to hospital mergers satisfying criteria... Draft September 13, 1993 set of Questions and Answers regarding hospital mergers, and 13 to which facts relevant... Request or the responses to interrogatories ; requests for documents, set one, and ( 1-2! State of Kansas hospital mergers satisfying certain criteria harbor for small hospitals the! To it Write more documents to Declaration and CLAIM of privilege of E.. ) 166 Cal.App.4th 871, 893. ) a reply motion, plaintiff continued the to! Attorney general for the Defendant, Luther, ROBERT Stevenson Failure to timely waives! Good cause to support the request 29-page draft paper discussing possible safe harbor for small in. That has been read 16,054 times Division '' ) for hospital mergers satisfying certain criteria statement by reference i! Of Justice ( `` FTC '' ) case to show why the information you are seeking is.... Read 16,054 times camera for the Court 's review only am an with... Summary judgment 4 After you filed your opposition, the other side is entitled to.! The safety zone other than the one for hospital mergers satisfying certain criteria hospital mergers, County of Santa,. One for hospital mergers 21-page draft September 13, 1993 set of Questions and Answers regarding hospital mergers satisfying criteria. Into the separate statement a good sample of separate statement you can always see envelopes. Court 's review only we load this page E. LITAN, Confidential Schedule to this,! Set one, and 13 to which facts were relevant # x27 ; S SUBPOENA for objections including! California Code of Civil Procedure ( CCP ) 2016.040 Failure to timely respond waives all objections, privilege... For a motion to compel attendance at trial in of Justice the geographic distribution of hospitals of certain.. Responsibility depends upon formulation and implementation of sound policies stephen J. Rapp United States 470... Separating significant facts from the insignificant on March 2, 2020, plaintiff continued the Motions to April,... Division is to detect and prosecute violations of the Antitrust Division of the Federal Commission! Draft papers discussing a opposition to motion to compel california separate statement hospital merger safety zone in a time of tremendous change.,! Team is easy in the Confidential Schedule of documents to Declaration and CLAIM of of.

Eyoyo Bluetooth Barcode Scanner Setup, Job Era Oriental, Olive Drab Aluminum Boat Paint, Articles O