If a party has timely served a Demand for Simultaneous Exchange of Expert Trial Witness Information pursuant to Code of Civil Procedure section 2034.210, then “all parties who have appeared in the action shall exchange information concerning expert witnesses
Katherine Gallo, Esq.
Katherine Gallo, Esq. is a legal professional specializing in complex discovery issues and alternative dispute resolution, including roles as a Discovery Referee, Special Master, and Mediator. With over 30 years of experience primarily in the Bay Area, she has been involved in numerous complex cases across various practice areas such as business, construction, employment, family law, insurance bad faith, personal injury, probate, product liability, and real property. Her work includes facilitating dispute resolution before motions are heard, managing discovery plans, and authoring educational content on discovery practices. She also serves as an approved California Bar MCLE provider and contributes to legal education through presentations and publications focused on discovery and dispute resolution.
Latest from Katherine Gallo, Esq. - Page 4
In Order to Facilitate the Discovery Process–Serve Your Discovery in Electronic Form
The biggest burden in bringing motions to compel further responses is the preparation of the separate statement of items in dispute pursuant to CRC, Rule 3.1345. In my blogs and at seminars, I have advised parties to prepare their…
Nail Down Whether the Documents You are Seeking ever Existed and Where They are Now
Assume you receive the following response to your Requests for Production of Documents:
Responding party hereby incorporates its general objections as if fully stated herein. Responding party objects to this request to the extent it seeks information protected from disclosure…
New Discovery Sanction Regarding Requests for Production of Documents
The greatest discovery abuses come from responses to Requests for Production of Documents. Many responses contain a myriad of garbage objections, fail to contain a privilege log, along with producing documents that are not organized by category. Due to the…
Make Sure You are Aware of the New Document Response Requirements
If Plaintiff’s Bill of Particulars is Improper, Evasive and/or Incomplete; You must Bring a Motion or You Waive Your Objections
As stated in the blog “It’s Not a Discovery Device, But…”, a Demand for Bill of Particulars is NOT a discovery device, but an extension of the complaint or a cross-complaint [complaint]. Unlike interrogatories and deposition testimonies, a Bill…
When Will My Discovery Motion Be Heard?
Pre-trial Discovery is the heart and soul of litigation. It enables the parties to evaluate and prepare their case for mediation, motions for summary judgment or summary adjudication and for trial. The propounding of Discovery also leads to discovery disputes…
Civil Litigation and COVID-19: Justice Need Not Be Delayed
Life as we knew it has been put on hold due to COVID-19. Courts are closed, deadlines are extended, and court dates have been continued. As the courts establish “new norms” for their operations, access to the civil courts…
Know Your Audience
Recently at an MCLE seminar, a sitting judge forewarned the audience that because of all the new judges coming from a variety of backgrounds, often they don’t have the necessary background on law and procedures for their department. His advice:…
How Much is that Motion in the Window?
The meet and confer process has failed. Now you have to decide whether (1) you need to bring a Motion to Compel Further Documents because the documents are an integral part of the defense and/or prosecution of your case, or…
