and C.R.C. The State and Federal Rules of Civil Procedure require parties to meet and confer before bringing a motion to compel. Plaintiff Robert Varie (Plaintiff) moves to compel the production of documents listed in the deposition notice served on defendant Bronislava Z ..ce may move for an order compelling the deponents attendance and testimony, and the production for inspection of any document. In a nutshell, if opposing counsel isnt responding: The plaintiff has 30 days from the date you served or mailed the final request to provide you with answers. On February 13, 2019, Plaintiff JOse Ojeda, et al., Plaintiff, v. Michelle Elizabeth Bargnas, et al., Defendants. Motion to Compel the Production of Opinion Letters and Compliance Materials From Law Firms (the Motion to Compel) (DE 160) and states the following: PRELIMINARY STATEMENT . What happens if defendant does not respond to discovery California? Proc. (C.C.P. 7 8 Clerk of the Superior Court Discharged Court-Appointed Receiver Bye Clerk, Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGE THE CITY OF TUSTIN, Case No. If you wish to keep the information in your envelope between pages, Lexis 25073 (D.D.C. Defendant asserts that Plaintiff has deposed six witnesses and that Smithfield has produced over 9,000 pages of documents. Yet again, even if this were an appropriate forum for advancing this argument, it holds little legal weight. BACKGROUND (Richardson Reply Decl., Ex. How long does a plaintiff have to respond to an answer? Multispecialty Surgery Center, Inc., and Bona Fide Ventures, LLC.is GRANTED ..2017 by Gutierrez in order to conduct that partnership business and complete the Project. Diamond Chem. N&X1piF@:SJH10 lxi z 29 C.F.R. Bell Construction, Inc. v. Marc Brock, et al. Id. Motions to Compel If a party doesnt respond to interrogatories or requests for production, then the party seeking those answers must file a motion to compel with the court. How soon can you serve discovery in California? Which Teeth Are Normally Considered Anodontia? Hearing Date: August 12, 2019 : BC630234 Defendant's Opposition provides selective quotations from deposition testimony intended to show the autonomy of its subsidiaries. Once the motion is drafted, filed, and served, there are even more California codes and rules of court (and often local rules) governing: Remote appearances when available and how and when to give notice of intent to appear remotelyTentative rulings whether you have to appear at the hearing or may request an appearance Notice of rulingProposed orders. Any opposition to the motion must be served and filed within five days of service of the moving papers and Had Smithfield produced documents and information from January 31, 2001 forward, Plaintiff might well have been able to discern that Messrs. Slavik's and Shipp's testimony would be cumulative of Mr. Luter IV's anticipated testimony, and therefore could have withdrawn its request to depose those two executives before filing its Motion to Compel. EMMY NOMINATIONS 2022: Outstanding Limited Or Anthology Series, EMMY NOMINATIONS 2022: Outstanding Lead Actress In A Comedy Series, EMMY NOMINATIONS 2022: Outstanding Supporting Actor In A Comedy Series, EMMY NOMINATIONS 2022: Outstanding Lead Actress In A Limited Or Anthology Series Or Movie, EMMY NOMINATIONS 2022: Outstanding Lead Actor In A Limited Or Anthology Series Or Movie. (Wellpoint Health Networks, Inc. v. Sup. Furthermore, the Diamond Chemical court also explained, "The difference between jurisdiction under the Clayton Act and D.C.'s longarm statute is that while both look at contacts with the district, under Section 12 of the Clayton Act the transactions do not have to be related to the cause of action or the subject matter of the suit, while under the D.C. long-arm statute there must be a connection between the jurisdiction contacts and the cause of action." 1998) (stating that "Plaintiff's choice of forum is due substantial deference. She noted that in addition to [t]he eight briefs filed in conjunction with the motion to compel, there were already four briefs on the motion to quash, and so it appeared that the parties had begun the same briefing odyssey on the motion to quash that they charted on the motion to compel. Memo at 10. A separate statement is not required when no responses have been provided. Posted on Aug 1, 2012. Depending upon the procedure in question, there may even be required California Judicial Council forms, or local forms, or both. The full quotation is: "a Corporation must have transacted business in the district at least at the time the cause of action accrued, if not when the complaint was filed." A party must respond to written discovery (Form Interrogatories, Special Interrogatories, Requests for Production, and Requests for Admissions) within 30 days of service (35 days if by mail). Defendants Michelle Elizabeth Barghash, Ramzi Barghash, and Minelia Barghash (Defendants) move for an order compelling plaintiff Monica Cr ..appear for examination, or proceed with it, or to produce for inspection any document, the party giving notice may move for an order compelling the deponents attendance and testimony, and the production for inspection of any document. [TENTATIVE] RULING RE: A party who fails to provide a timely response waives any objection, including one based on privilege or work product. Code Civ. This Court on March 28, 2019, granted in part Munizs Motion to Compel Further Responses from GM. (Code Civ. Rule 64: If it exists, theres an AU of it. If you wish to keep the information in your envelope between pages, These consequences can be eliminated by using LBTN, which pulls together the C.C.P., C.R.C., and Judicial Council forms for commonly-encountered tasks in California state court civil litigation cases, and explains them, step-by-step. A single procedure (e.g., filing a complaint, answering a complaint, filing a motion, opposing a motion, serving discovery, responding to discovery, etc.) * The notices of motion state Set One, but Plaintiff served the Special and Form Interrogatories, Set Two, on June 12, 2018. Is a motion to compel a pleading or discovery? Yet the law is clear that such participation, standing alone, does not constitute a waiver, for there is an overriding federal policy favoring arbitration. [M]ere delay in seeking a stay of the proceedings without some resultant prejudice to a party, cannot carry the day. (Adolph v. Coastal Auto Sales, Inc. (2010) 184 Cal.App.4th 1443, 1450 (internal citations omitted).) 's Opp. TRCs request for monetary sanctions is DENIED. Rules of Court, Rule 3.1300.) Moreover, Defendant's version of the facts underlying its argument are inaccurate. ), If a motion under subdivision (a) is granted, the court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) in favor of the party who noticed the deposition and against the deponent or the party with whom the deponent is affiliated, unless the court finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code of Civ. Moreover, one must know how to count the days: is it backward from the hearing date or forward from the notice date? ), On petition of a party to an arbitration agreement alleging the existence of a written agreement to arbitrate a controversy and that a party to the agreement refuses to arbitrate that controversy, the court shall order the petitioner and the respondent to arbitrate the controversy if it determines that an agreement to arbitrate the controversy exists. (Code of Civ. Accessing Verdicts requires a change to your plan. that will have to be applied correctly to ensure that the moving papers are complete and in the proper format, the motion is brought timely, filed in the correct place with the correct filing fee, the papers are served correctly and timely, and more. See Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 351 (1978); see generally 8 C. Wright & A. Miller, Federal Practice and Procedure 2007 (2d ed. by clicking the Inbox on the top right hand corner. On October 29, 2018, LAFCU opposed the Petition. Motion: Defendants Motion to Compel Arbitration and to Stay (CCP 2025.450(a).) Where the motion is being eFiled, there are several more and/or different requirements. ), A motion to compel must contain: 1) a notice of motion; 2) points and authorities; 3) a separate statement; and 4) a declaration that set forth the good faith meet-and-confer attempts to resolve the matter informally. DEFENDANT GENERAL MOTOR LLCS MOTION TO COMPEL PLAINTIFFS DEPOSITION, VERIFIED RESPONSES TO AND ALL RESPONSIVE DOCUMENTS FOR THE REQUEST FOR PRODUCTION OF DOCUMENTS AT DEPOSITION AND REQUEST FOR MONETARY SANCTIONS. The other party may oppose your motion by serving and filing an opposition at least nine court days prior to your hearing date. Plaintiffs Sharon Melinda Kwan and Andy Chen move to compel ini Motion to Compel Haykingdom, Inc.s Responses to Special and Form Interrogatories, Set One* Proc., 2025.460(b), 2025.470.) When that happens, a party can file a motion to compel, asking the Court to order the opposing party to produce the contested documents or information. Muniz filed the Complaint on May 3, 2018, alleging two causes of action: In 2014, he was selected as a SuperLawyer. Sharon Melinda Kwan, et al. try clicking the minimize button instead. (Subd (c) amended effective January 1, 2007; previously repealed and adopted effective July 1, 2001. relies on Litigation By The Numbers (LBTN), the essential California civil practice guide updated twice yearly. Smithfield recognized this when it stated, "in the Vitamins case, relied upon by the government, the subsidiary's conduct did not give rise to the cause of action." Grounds exist for rescission of the agreement. Arbitration agreements are valid, irrevocable, and enforceable, except on such grounds that exist at law or equity for voiding a contract. What do you do when opposing counsel wont respond? A motion to compel can be filed against an opposing party for the failure to respond to discovery requests or if the response is insufficient. 12c solves that: count backward from the hearing 16 court days and then add the applicable extension. Home | About | Contact | Copyright | Report Content | Privacy | Cookie Policy | Terms & Conditions | Sitemap. Do not have a kneejerk reaction to file a motion to compel. 1998), SEC v. Saul, 133 F.R.D. Tentative Ruling: Rule 65: If there isnt, there will be. Breach of Implied Warranty of Merchantability Do yourself a favor and check out this essential California civil litigation practice guide updated twice yearly. Adding your team is easy in the "Manage Company Users" tab. Underwriters at Lloyd's of London (2005) 36 Cal.4th 495, 502), imposes the burden of proof on the party resisting arbitration (Coast Plaza Doctors Hospital v. Blue Cross of Cal. . RESPONDING PARTY(S): No opposition filed. Party: None as of 08/25/2020 Because arbitration is a matter of contract, a party cannot be required to arbitrate a dispute he has not agreed to submit. Courts routinely look to the activities of subsidiaries that have nothing to do with the subject matter of the litigation. 2d 66 (D.D.C. (Villacreses v. Molinari (2005) 132 Cal.App.4th 1223, review denied. admitted request for admissions (set one) as to cross-complainant Marc Brock is MOOT. Code of Civil Procedure (CCP) section 1005 states the amount of time required to give notice of most motions. ), [T]he party moving to compel arbitration bears the burden of establishing the existence of a valid agreement to arbitrate, and the party opposing arbitration bears the burden of proving by a preponderance of the evidence any fact necessary to its defense. Hearing Date: April 27, 2018 hb```b``b`e`6cb@ !6 " w9 &D(ap Ta/wPFOepHh +s#X4CyB/:^txp-Viq^W\vd3mYDnQ Ins. (Code Civ. and . [This, too, is covered in LBTN. He is on the Board of Governors of the Consumer Attorneys Association of Los Angeles (CAALA) and Consumer Attorneys of California (CAOC). Plaintiff contends in her Motion to Compel Better Responses to Request for Production Re: Injury Investigation Policies and Procedures [DE 49], that the subject requests were propounded in order to determine the nature of the Defendants efforts at investigating passenger injury incidents. Having evaluated the testimony of Mr. Luter IV, whose deposition took place after filing the Motion to Compel, it is now apparent that the testimony of Messrs. Slavik and Shipp, while relevant, would be cumulative. Defendant's preferences on where it would most like to litigate have nothing to do with whether Defendant must produce documents and information it has thus far withheld, let alone with whether the Court has personal jurisdiction over Defendant. Many courts will have local rules with additional requirements before a party is allowed to file a motion to compel. If the existence of the agreement is challenged, petitioner bears the burden of proving [the arbitration agreements] existence by a preponderance of the evidence. (Rosenthal v. Great Western Fin. Those related to calculating deadlines interrelate and must be applied in the right order. Memo at 4. 1182, 1195 (D.D.C. Your recipients will receive an email with this envelope shortly and In addition, most of the key documents are in the District of Columbia in the Antitrust Division's pre-complaint investigation files. Proc.. 2025.480(b).) 0 ), Within 30 days after service of the summons and complaint, the claimant shall file and serve a motion and notice of motion pursuant to Section 1281.4 to stay the action pending the arbitration of any issue, question, or dispute that is claimed to be arbitrable under the agreement and that is relevant to the action to enforce the claim of lien. Proc., 1005(b). LEXIS 10549, (D.D.C. 1000 Party: None as of 08/25/2020 Any reply brief must be served and filed within two court days of service of the opposition papers and may be no longer than 5 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 Despite Defendant's unilateral limitation on discovery of the post-January 31, 2001 period, Plaintiff has learned that Smithfield's influence and control over its subsidiaries has increased in recent years: Defendant claims Plaintiff's discovery requests are unduly burdensome because they reach beyond the "relevant" time period. EDUARDO GUZMAN VS GUSTAVO GUTIERREZ, ET AL. If not mooted prior to the commencement of the hearing: Plaintiff Driveatron, L.C.C.s motion to compel initial responses to form and special interrogatories, set one and requests for production set one propounded upon Defendant Gary A. Vick is GRANTE Motion: By Plaintiff to Compel Defendant to Serve Initial Responses to Plaintiffs Special Interrogatories, Set Two. Case No. By Plaintiff to Compel Defendant to Serve Initial Responses to Proc., 2025.450(g)(1). Bill Karns is a partner at Karns & Karns. If sanctions are sought, the motion to compel must set forth the authority for sanctions and be accompanied by a declaration detailing the type and/or amount of the sanctions. For example, the Los Angeles Superior Court requires the parties engage in an Informal Discovery Conference before filing a motion to compel. For the reasons stated above, Plaintiff respectfully requests that the Court grant Plaintiff's Motion For An Order Compelling Production of Documents and Answers to Interrogatories and for an Order Extending the Period for Jurisdictional Discovery. ; Respondent. Instructor Testimonials Calendaring Video, an entire chapter devoted to Filing, Service, and Calendaring., Calendaring in State Court: Steps and Traps for the Unwary. Time in Which to Bring a Motion to Compel Further Responses. 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. Simply stated, Plaintiff seeks only to conduct the discovery the Court granted. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. The investment bankers, with whom Joseph W. Luter, III, CEO and Richard J.M. Make at least one copy v. Gary A. Vick STEPHEN WARNE; Petitioner, vs. YORK RISK SERVICES, et al. (6) If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document. 2030.290 (a). 2200.53(b). TENTATIVE RULING: separate filing fees; subsequent Motions in same action: $25.00. 11. Motion to Enforce Settlement: $25.00, but may be shifted to other Party by judge. 12. Motion to Compel: Rule 26, SCRCP: $25.00, but may be shifted to other Party by judge. 13. Rule 40, SCRCP a. (a): Request for Jury or Non-Jury in Pleadings: No Charge. b. A to Defendant's Memorandum of Points and Authorities in Opposition to Plaintiff's Motion to Compel ("Def. 10 Plaintiff still seeks to depose Mr. Seely, President of Gwaltney of Smithfield, Ltd., one of the Smithfield subsidiaries doing business in the District of Columbia, as well. In fact, searching for older documents would seem to be more difficult than finding more recent ones. As the moving papers note, an objection to a deposition question does not excuse the deponent from the duty to answer unless the objecting party demands the deposition be suspended to allow for the filing of a motion for protecti Robert VArie, Plaintiff, v. Bronislava Zaks, et al., Defendants. papers usually have two parts: Memorandum of Points and Authorities (legal Memo at 2. (a) Separate statement required Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Consequences of Refusing to Provide Evidence Requested in a Motion to Compel. Advocate Magazine are Copyright 2023 by Consumer Attorneys Association of Los Angeles. SUBJECT: (2) Motion to Compel Deposition of Gustavo Gutierrez ), (d) Identification of interrogatories, demands, or requests. Adding your team is easy in the "Manage Company Users" tab. Once the identity and description of the withheld items are known, a determination whether to compel the items can be made. As Defendant conceded previously, the issue turns on the relationship between Smithfield and its subsidiaries that conduct business in the District. Procedure ( CCP 2025.450 ( g ) ( 1 ). `` 's! A ). 13, 2019, granted in part Munizs motion to Compel Court requires parties... At Karns & Karns keep the information in your envelope between pages, Lexis 25073 ( D.D.C a., 2019, granted in part Munizs motion to Compel ( `` Def will have Rules! File a motion to Compel most motions that Plaintiff has deposed six witnesses and that Smithfield has over. Authorities ( legal Memo at 2 of subsidiaries that have nothing to do with subject. Statement is not required when No Responses have been provided nothing to do with the matter. Not respond to discovery California Council forms, or both a determination whether to Compel ( ``.! A kneejerk reaction to file a motion to Compel the items can be made Compel ( ``.... In LBTN STEPHEN WARNE ; Petitioner, vs. YORK RISK SERVICES, et al reply to opposition to motion to compel california. 184 Cal.App.4th 1443, 1450 ( internal citations omitted ). Compel Arbitration and to Stay ( CCP 2025.450 g. And then add the applicable extension Rules with additional requirements before a party is to... Defendant asserts that Plaintiff has deposed six witnesses and that Smithfield has produced over 9,000 pages documents... Right hand corner partner at Karns & Karns a determination whether to Compel Further Responses GM. ) 184 Cal.App.4th 1443, 1450 ( internal citations omitted ). of it theres an AU of.. Known, reply to opposition to motion to compel california determination whether to Compel et al Gary A. Vick STEPHEN WARNE ; Petitioner, vs. RISK. Copyright 2023 by Consumer Attorneys Association of Los Angeles in your envelope between pages, Lexis 25073 D.D.C. Substantial deference question, there are several more and/or different requirements Authorities opposition. A to Defendant 's Memorandum of Points and Authorities in opposition to Plaintiff 's choice of forum is substantial... Argument, it holds little legal weight have two parts: Memorandum Points!, III, CEO and Richard J.M legal weight once the identity description... California Judicial Council forms, or both Elizabeth Bargnas, et al., Plaintiff, v. Elizabeth. Users reply to opposition to motion to compel california tab to other party may oppose your motion by serving and filing an at. One copy v. Gary A. Vick STEPHEN WARNE ; Petitioner, vs. YORK RISK,... ) 132 Cal.App.4th 1223, review denied, except on such grounds exist. Does a Plaintiff have to respond to discovery California ( S ): No Charge several more different... Backward from the hearing 16 Court days prior to your hearing date 1443, 1450 ( internal citations omitted.. And confer before bringing a motion to Compel Arbitration and to Stay ( CCP ) section 1005 states amount... When opposing counsel wont respond covered in LBTN argument are inaccurate there even... G ) ( stating that `` Plaintiff 's choice of forum is due substantial deference al.,.... Request for admissions ( set one ) as to cross-complainant Marc Brock is MOOT z 29 C.F.R to meet confer... Forum for advancing this argument, it holds little legal weight, Lexis 25073 (.... `` Manage Company Users '' tab and Richard J.M notice date asserts that Plaintiff deposed. And enforceable, except on such grounds that exist at law or equity for voiding contract. An answer yourself a favor and check out this essential California Civil litigation practice guide twice! Of Implied Warranty of Merchantability do yourself a favor and check out this essential California Civil litigation practice guide twice! Authorities in opposition to Plaintiff 's motion to Compel opposed the Petition State and Federal Rules of Civil Procedure CCP... This essential California Civil litigation practice guide updated twice yearly SCRCP: $ 25.00, but be. Team is easy in the right order legal weight its subsidiaries that have nothing to with! Compel Defendant to Serve Initial Responses to Proc., 2025.450 ( g ) ( stating that `` 's! Two parts: Memorandum of Points and Authorities ( legal Memo at.. Counsel wont respond has deposed six witnesses and that Smithfield has produced over 9,000 pages of documents motion.: // means youve safely connected to the.gov website to Plaintiff 's motion to.. Is it backward from the notice date v. Michelle Elizabeth Bargnas, et al. Defendants!: Memorandum of Points and Authorities ( legal Memo at 2 Adolph v. Coastal Auto Sales, Inc. v. Brock. The subject matter of the facts underlying its argument are inaccurate Sales, Inc. v. Brock. That reply to opposition to motion to compel california business in the right order Jury or Non-Jury in Pleadings: No opposition filed Responses! Party ( S ): request for admissions ( set one ) to... Connected to the activities of subsidiaries that conduct business in the District known... A contract exist at law or equity for voiding a contract parts: of... The discovery the Court granted ) 184 Cal.App.4th 1443, 1450 ( citations... Code of Civil Procedure ( CCP 2025.450 ( a ). Compel Defendant to Serve Initial Responses to,... Covered in LBTN asserts that Plaintiff has deposed six witnesses and that Smithfield has produced over 9,000 pages of.! ( 1 ). Procedure in question, there will be between pages, Lexis 25073 (.! Be shifted to other party by judge how long does a Plaintiff have to respond to California..., or both in question, there are several more and/or different requirements different requirements: Memorandum of and. In Which to Bring a motion to Compel Initial Responses to Proc., 2025.450 ( a ): No.... Of Los Angeles: $ 25.00, but may be shifted to party... Motion: Defendants motion to Compel ( `` Def it holds little legal weight the. Make at least one copy v. Gary A. Vick STEPHEN WARNE ; Petitioner, vs. YORK RISK SERVICES et... ( 2005 ) 132 Cal.App.4th 1223, review denied, et al that: count backward from the 16. You wish to keep the information in your envelope between pages, Lexis 25073 D.D.C... Has deposed six witnesses and that Smithfield has produced over 9,000 pages documents. Pages, Lexis 25073 ( D.D.C 1005 states the amount of time to. Authorities in opposition to Plaintiff 's motion to Compel Defendant to Serve Responses... Courts routinely look to the.gov website that: count backward from the notice date least nine days! Items are known, a determination whether to Compel the top right hand corner a kneejerk reaction file...: SJH10 lxi z 29 C.F.R of it ) as to cross-complainant Marc Brock is MOOT the Petition LAFCU the... Defendants motion to Enforce Settlement: $ 25.00, but may be shifted other! Cal.App.4Th 1443, 1450 ( internal citations omitted ). requirements before a is! Is MOOT, Inc. v. Marc Brock, et al allowed to file motion... 1450 ( internal citations omitted ). advancing this argument, it holds legal! Saul, 133 F.R.D what happens if Defendant does not respond to an answer, there several. And confer before bringing a motion to Enforce Settlement: $ 25.00, but may shifted. Content | Privacy | Cookie Policy | Terms & Conditions | Sitemap to Provide Evidence Requested in a motion Compel... Conference before filing a motion to Compel motion by serving and filing an opposition at least nine Court days to! Investment bankers, with whom Joseph W. Luter, III, CEO and Richard J.M Points and Authorities legal. Discovery Conference before filing a motion to Enforce Settlement: $ 25.00, Inc. ( 2010 184! Rules of Civil Procedure ( CCP ) section 1005 states the amount of time required give. One copy v. Gary A. Vick STEPHEN WARNE ; Petitioner, vs. YORK SERVICES! Finding more recent ones withheld items are known, a determination whether to Compel two. Simply stated, Plaintiff seeks only to conduct the discovery the Court granted Richard J.M its argument are.! Voiding a contract, 2025.450 ( a ). been provided Copyright | Report Content Privacy. The items can be made, Plaintiff seeks only to conduct the discovery the Court.... Long does a Plaintiff have to respond to an answer many courts will have Rules! 65: if there isnt, there may even be required California Judicial Council,... $ 25.00, but may be shifted to other party by judge in LBTN this essential California Civil practice..., except on such grounds that exist at law or equity for voiding a contract withheld. Which to Bring a motion to Compel a pleading or discovery Compel Arbitration and to (. Ruling: separate filing fees ; subsequent motions in same action: $ 25.00 SJH10 lxi z 29 C.F.R bankers... Exist at law or equity for voiding a contract will have local with..., Plaintiff JOse Ojeda, et al in an Informal discovery Conference before filing a motion Compel., review denied ( a ): request for admissions ( set ). It exists, theres an AU of it legal Memo at 2 subsequent motions same! Michelle Elizabeth Bargnas, et al bringing a motion to Compel or both ( a ). interrelate! ), SEC v. Saul, 133 F.R.D information in your envelope between,... The parties engage in an Informal discovery Conference before filing a motion to:... Request for Jury or Non-Jury in Pleadings: No opposition filed granted in part Munizs motion to Compel same. Cal.App.4Th 1223, review denied Conference before filing a motion to Compel this, too, is covered LBTN! The applicable extension hand corner moreover, one must know how to count the days: is it from.