UPDATED January 4, 2023
Effective January 1, 2023, Caifornia Code of Civil Procedure § 2016 which authorized authorized the court to conduct an informal discovery conference upon request of a party or on the court’s own motion was REPEALED.
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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.
Website:
https://discoveryreferee.com
Latest from Katherine Gallo, Esq. - Page 5
EXHIBIT A—The Meet and Confer Letter
The purpose of the “meet and confer” requirements set forth in C.C.P. §§ 2025.450(b)(2), 2025.480, 2030.300(b), 2031.310(b), 2032.250 and 2033.290 was for the lawyers to revisit their position, and in good faith, discuss a resolution in…
WHY THESE OBJECTIONS ARE GARBAGE
In the previous blog, Start Preparing Your Motion Because with These Responses You’re Going to Court, I used the following example as a type of response I see as a Discovery Referee:
Responding party hereby incorporates its general objections as…
Start Preparing Your Motion Because with These Responses You’re Going to Court
Have you noticed that you are getting too many objections and very little documents to your document requests? Have you also noticed that despite months of meet and confers you still don’t have a determination whether or not documents exist;…
Should You Amend Your Interrogatory Responses?
It’s not required that a party amend interrogatory responses to reflect information the party got after responding, but there are situations in which a party may want to do just that.
Here’s why it may be a good…
When Opposing Counsel Tries to use Improper Supplemental Disclosures to its Benefit, Here’s How to Fight Them
Alexandra A. Hamilton, a trial attorney at The Veen Firm, who handles complex cases involving catastrophic injuries or death, including products liability, workplace injuries, dangerous conditions of property, and vehicle negligence has written a great article for Plaintiff…
Gathering Valuable Crumbs from a Party’s Mobile Devices
Another great article from Julie Lewis, President, CEO and Founder of Digital Mountain regarding obtaining information from a party’s iPad’s, smart phones and other mobile devices.
Social Media Metadata on Mobile Devices: Gathering Valuable Crumbs
If you’re a fan…
Ten Tips for Successful eDiscovery Planning
Julie Lewis, President, CEO and Founder of Digital Mountain, has over 20 years of experience working in the high technology industry and is a frequent speaker on electronic discovery, computer forensics and cybersecurity. After working on over 1,000…
Can a Motion for Protective Order be Filed after the Court has Issued its Order?
About a year ago I received an inquiry from a lawyer stating:
I’m researching whether the defendant can file a motion for a protective order after my motion to compel was already granted—I’m’ trying to find a case that precludes…
Opposing Counsel is Blowing Smoke
A plaintiff counsel writes in asking for advice:
“Today is July 7th. Trial is July 31. Discovery cut-off was July 1 and expert discovery closes on July 16th. Well, my client sought additional treatment on June 25thwith a neck, back…