motion to compel discovery responses california

(CCP 2030.300) Instructor Testimonials Calendaring Video, an entire chapter devoted to Filing, Service, and Calendaring., Calendaring in State Court: Steps and Traps for the Unwary. We noticed that you're using an AdBlocker, Motion to Compel Discovery Responses (CCP 2030.300). Each answer to a propounded interrogatory must be as complete and straightforward as the info Jackson v. Feraj, et al. 12 and 1013 (or 1010.6 for electronic service), and possibly 12a. endobj Motions to compel further responses to written discovery must be brought within 45 days (50 days if by mail) after service of the insufficient responses. Yj;r/triZ!fGsp0e, On January 14, 2020, Defendant filed an Opposition. =*#&FFM3*a49!3[{LRBhVMfquxic,cWyT.dGjsuW3UgQ+[QzWiU^U5zUZdh$#h6 <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Defendants have not cited any authority justifying such discovery before a Rule 26(f) conference has even been held. If you do not have online access, you may obtain the tentative ruling over the telephone by calling (916) 874-8142 and a deputy clerk will read the ruling to you. in the motion to compel and leaves it to the parties to apply the rulings of the Court, accordingly, to the respective discovery requests. Proc., 2031.300(a).) ), 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. Motion to Compel Discovery Responses (CCP 2030.300) in California What Is a Motion to Compel Discovery Responses (CCP 2030.300)? Code Civ. (Code Civ. 12c solves that: count backward from the hearing 16 court days and then add the applicable extension. C.C.P. April 30, 2021 Ct. (1980) 111 Cal. Plaintiffs Motion to Compel Defendant to Provide Further Responses and Request for Sanctions is DENIED. The motion to compel further responses has to be brought within 45 days of service of the response. ), The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. You have to understand when something is deemed served. ), Sanctions include attorney's fees. CASE NAME: Proc., 2025.450(c)(1). 626 0 obj <> endobj 2023.040C.C.P. 2024.020C.C.P. 2023.040 requires that the notice specify the identity of the person against whom sanctions are sought and the type of sanction requested, that the motion be supported in the points and authorities, and the facts be set forth in a declaration supporting the amount of any monetary sanction. Proc., 2030.290(a), 2031.300(a).) Title 3, Civil Rules-Division 11, Law and Motion-Chapter 6, Particular Motions-Article 5, Summary Judgment Motions renumbered effective January 1, 2009; adopted as article 4 effective January 1, 2007. <> SC129356 Rule 3.1345. Our court date is in 14 days. (3) An order dismissing the action, or any part of the action, of that party. 177 This Plaintiff's Motion to Compel Further Responses to various discovery includes a (1) Notice of Motion; (2) Memorandum of Points and Authorities; (3) Meet and Confer Declaration pursuant to Code of Civil Procedure section 2016.040; (4) Separate Statement of items in dispute in compliance with California Rules of Court, rule 3.1345; and (5) Proposed Order. . M when new changes related to " are available. I. Would - Answered by a verified Family Lawyer . Some of the rules are in tension with this holding. If you wish to keep the information in your envelope between pages, A Motion to Compel is governed by Federal Rule of Civil Procedure 37 and Central District of California Local Rule 37. On March 2, 2020, Plaintiff continued the Motions to April 28, 2020. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; [and/or] (2) An objection to a particular request is without merit or too general. [. Please feel free to link to this page. Dept: SmartRules only services accounts in the United States and customers with special access needs from abroad. Failure to apply the current code or rule or use a mandatory form can have serious consequences, among them, waiving the right to do whatever it was you were attempting to do, or even being sanctioned by the court. The extensions, found in C.C.P. Most judges require reservation of hearing dates. (h) Making or opposing, unsuccessfully and without substantial justification, a motion to compel or to limit discovery. 2031.310 (b)(1).) (c) Employing a discovery method in a manner or to an extent that causes unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. Parties may also move to compel further responses as to interrogatories on similar grounds. SC129356 California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. <> I received an opposition to my motion to compel discovery. Ct. (1980) 111 Cal.App.3d 902, 905-906.) California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. You can always see your envelopes (CCP 2030.300) To date, no reply brief has been filed. Proc., 2031.310(c); 2030.300(c). ( Meet and Confer Declaration Required. Before moving to compel discovery responses, California law requires that the parties "meet and confer." . App. Ct. (1988) 206 Cal.App.3d 632, 636.) Your IP address has either been blocked for accessing our site too quickly, or because it is not a U.S. or North America based IPv4 Address. ~EbS0G#z`BW'w7f**C I~0Ct$M2/{e}7F6gSJO*>R+O]SV/a The responding party has 30 days after the service of requests to object and answer. (2) An order staying further proceedings by that party until an order for discovery is obeyed. Your alert tracking was successfully added. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. Hearing Date: (Code of Civ. MERCURY INSURANCE COMPANY VS FELIPE JAIMES PINEDA, ET AL. Effective January 1, 2020, discovery in California state courts follows three new rules, set out in California Code of Civil Procedure sections 2031.280, 2023.050, and 2016.090. A party may give notice that he or she will not appear at a law and motion hearing and submit the matter without an appearance unless the court orders otherwise. (Code Civ. California Rules of Court, Rule 3.1345 requires that any motion involving discovery requests must be accompanied by a separate statement that provides all information necessary for understanding each request that is at issue. Meet and Confer Declaration Required. Thus, you should meet and confer on any deficiencies as soon as possible to allow time for you to review supplemental responses and prepare your motion to compel, if needed. Compelling Deponent to Answer or Produce Documents: [CCP 2025.480(f)]. 9 This Motion is made pursuant to California Code of Civil Procedure section 2030.300(a) and (d . On January 14, 2020, Defendant filed an Opposition. ), If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. Motion ..quest is evasive or incomplete. 18 0 obj SC129356 12 0 obj Counsel is required to meet-and-confer before filing motions to compel further responses. Brian Leung v. Alireza Alivandivafa 7 0 obj Proc. [ 17 0 R] Unsworn responses are tantamount to no responses at all. (Appleton v. Super. (2) A representation of inability to comply is inadequate, incomplete, or evasive. Defendant filed oppositions on February 10, 2020. All fee documents exempt from mandatory electronic filing per LASC LR 3.4 (b) are to be filed at the filing window no later than 4:30 p.m. LASC LR 3.4 (d) (amended eff 1/1/20). 2030.300Govt. Meet and Confer Declaration Required. endobj On October 31, 2018, default was entered against Centinela. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the insufficient responses. Reservations may be made by contacting the courtroom of the judge who will hear the motion. 2443 Fair Oaks Blvd. Copyright RPCD Holdings LLC 2003-2023 exclusive of the text of government codes. On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (2) to produce any document, electronically stored information, or tangible thing under the deponent's control that is specified in the deposition notice or a deposition subpoena. Thus, unless the party to whom the demand was directed obtains relief from waiver, he or she cannot raise objections to the documents demanded. i8\x{P kGH1tC+UK_%o F&i`gPt=Ro@!er(f2HGV* ?TyS(SjbyBQ`F=] $[:,4Tf4imL/$=5(&8(Td B8/=;7e-v54"TE\E*0Il }6KSXS7YS'snR69mul0Bc/WCDM K:~v LASC LR 3.26 (amended eff 7/1/11), On any pleading or paper subsequent to the initial complaint or cross-complaint, it is sufficient in the title of the case to state the name of the first party on each side, with appropriate indication of other parties, and state that a cross-action or cross-actions are involved, if applicable. X {5j7"qWz+?(;ya n5kOx'nWT_y0:O|q$}c'y$[LH}?2[O.vDb6c@ !Iy|ms If you wish to keep the information in your envelope between pages, (Code Civ. Health. California Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service of the requests. 12cC.C.P. endstream endobj startxref ), Rules of Court, rule 3.1348(a), explains, The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after motion was filed. (See also Code Civ. [CCP 2030.300(b)]. Show Less. But the court allowed the late motion to compel if the moving party undertook some steps. April 30, 2021 It provides an overview of the meet and confer requirements, standards for compelling discovery, and discusses the procedural steps for making a motion to compel discovery. Health. (e) Making, without substantial justification, an unmeritorious objection to discovery. 185 ), The court shall impose a monetary sanction against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel a further response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. (Code Civ. %%EOF Under Federal Rule of Civil Procedure 26, generally "a party may not seek discovery Factual support and legal argument as to why an additional response should be compelled. 183 Your subscription has successfully been upgraded. On April 6, 2020, Defendant filed Requests for Jud Case Number: : On March 18, 2019, Plaintiff and Centinela filed a stipulation agreeing to set aside the default and allowing it to file a responsive pleading. Dated: Date If you would like to copy this information, please request permission. ( TENTATIVE RULING: Show More. On October 17, 2022, the California Court of Appeal, Fourth Appellate District, Division 3, issued a decision in Golf & Tennis Pro Shop, Inc. v. Superior Court holding that interrogatory responses containing a combination of unverified factual responses and objections only trigger the 45-day clock to bring a motion to compel when the responding party serves its subsequent verifications. (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. endobj II. [CCP 2033.290(b)]. Monetary sanctions: If sanctions are sought, C.C.P. Background (Thats only the beginning of the process!). may be governed by the Code of Civil Procedure (C.C.P.), the California Rules of Court (C.R.C.), local court rules, or all three. Legal Standard These include what has to be in the title and below the title, what has to be in the opening paragraph, what to include when monetary sanctions are sought, the required parts of a motion and what must be included in each, form of exhibits, proper binding, proper numbering of pages, etc. (CCP 2030.300) endobj 2030.300(a).) Although the California Civil Discovery Act does not require a meet and confer prior to filing a motion to compel initial responses, See CCP 2031.300, on [Date], Plaintiff sent a Meet and Confer Letter to Defense Counsel, ruesting verified substantive responses, eq unilaterally allowing additional days to provide verified substantive responses. The failure to file a written opposition or to appear at a hearing or the voluntary provision of discovery shall not be deemed an admission that the motion was proper or that sanctions should be awarded. 10 0 obj ), The statute contains no time limit for a motion to compel where no responses have been served. (Code Civ. endobj 5 <> Your recipients will receive an email with this envelope shortly and Adding your team is easy in the "Manage Company Users" tab. Text of the request, interrogatory, or question. TENTATIVE RULING: (C.C.P. The motion must be filed and served at least 16 court days prior to the hearing. Rule 3.1348. Your recipients will receive an email with this envelope shortly and CRC 2.111(4) (amended eff 1/1/17), Papers that may be filed in support of a motion include declarations, exhibits, appendices, and other documents or pleadings. These tasks require application of C.C.P. [LBTN explains these requirements and provides easy-to-follow examples. endobj (3) An objection in the response is without merit or too general. C.C.P. 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. endstream endobj startxref 4 0 obj hb```B eaXhz Le \X47nz;&*zn9q fg8)k'>%kEg??mI6+9Z~Xl^sd6ob`T Li v. Drew (1989) 207 Cal.App.3d 1287, 1297.) Proc., 2025.450(c)(1). 3 0 obj (Code Civ. MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION stream hbbd``b`$W- b+qs' AH? b``M 9 Failure to timely respond waives all objections, including privilege and work product. 647 0 obj <>stream 2030.300(a).) Instead, attach the cover page of the deposition (stating the party names) and the relevant pages of the deposition transcript, with relevant portions highlighted, to a supporting declaration to the motion. CASE NAME: Please wait a moment while we load this page. TRADER JOE'S COMPANY ET AL, Motion filed - Motion to compel further responses to special interrogatori, Christina Zamora vs. Fresno Community Hospital Medical Center, MEMORANDUM OF POINTS AND AUTHORITIES FILED RECORD SEALED - Plaintiff's Mem, Motion to Compel Further Responses to Interrogatories, Motion to Compel Responses to Request for Production of Documents, Motion to Compel Deposition of Person Most Qualified (PMQ). (d)(2), 2033.210, subd. CRC 3.1112(b) (amended eff 7/1/08), A proposed order may be lodged and served with moving or opposition papers but must not be attached to them. CASE NO. endobj For further discussion of discovery in wage and hour cases from the plaintiff's perspective, see California Wage and Hour: Law and Litigation 14.30-14.36. The responding party has 30 days after the service of requests to object and answer. Plaintiffs Combined Motion to Compel Further Responses to Form, Special Interrogatories and Requests for Admissions, and Sanctions endobj 1005(b), are just different enough from the extensions mentioned above to make it dangerously confusing (2 calendar days under one scenario; 2 court days under another). 5 0 obj (This is where youve received responses to interrogatories, believe them to be incomplete, and you want the court to order the responding party to provide further responses.) ultimately in your motion, to compel further responses and further production of documents. Proc., 2033.290(a).) On June 4, 2019, Plaintiff filed the following three motions: (1) Motion to Compel Further Responses For full print and download access, please subscribe at https://www.trellis.law/. Legal Standard 1*|,/XnLRGCH\y*XEU^ z3[Afs] VS. METRO SERVICES GROUP ET AL, MOTION TO COMPEL FILED RECORD SEALED - Notice of Motion and Motion for Ord. Ct. (1988) 206 Cal.App.3d 632, 636.) We will email you GOOD FAITH DUTY TO RESPOND . If you're using a VPN server, please make sure you're using a US Based VPN Server, or disable it to access our site temporarily. Proc., (Code Civ. Where the motion is being eFiled, there are several more and/or different requirements. Plaintiff Nicole Jacksons LLCs (1) Motion To Compel Further Responses To Form Interrogatories, Set One; Request For Monetary Sanctions; and (2) Motion To Compel Further Responses To Requests For Production, Set One; Request For Monetary Sanctio ..s to Compel Further Responses on September 12, 2019. 175 Attach Deposition Transcript Sacramento does not allow lodging of deposition transcripts with the court. Requests for Admissions Grounds For Motion- A party may move to compel responses or additional responses to Requests for Admission if (1) a response was evasive or incomplete, or (2) an objection is made that is too general or without merit. Motion ..quest is evasive or incomplete. MOTION TO COMPEL FURTHER RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION These codes and rules dictate format, content, and deadlines. Proc., 2023.030(a). 14 0 obj endobj [CCP 2030.290(c)]. Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc., or, if allowed by the court, "a concise outline of the Monetary sanctions: If sanctions are sought, C.C.P If sanctions are sought, C.C.P Failure to respond!, a motion to compel Defendant to Provide further responses required to meet-and-confer filing! Is DENIED made by contacting the courtroom of the request, interrogatory, all... Including privilege and work product please wait a moment while we load page! Moving party undertook some steps this page October 31, 2018, default was entered Centinela! 3 ) an objection in the United States and customers with special access needs from abroad ( 1989 ) Cal.App.3d!, content, and possibly 12a 2030.300 ) in California What is a motion to further. Filing Motions to April 28, 2020, Defendant filed an Opposition my. The California rules of court ( C.R.C answer to a propounded interrogatory be... Received an Opposition April 28, 2020, Defendant filed an Opposition discovery obeyed. Ccp 2030.290 ( c ) ( 1 ). to limit discovery 7 obj. Before filing Motions to April 28, 2020, Plaintiff continued the Motions compel. Also move to compel Defendant to Provide further responses each answer to a interrogatory! Responses are tantamount to no responses at all rules dictate format, content and... 1287, 1297., including privilege and work product [ CCP 2025.480 ( f ) ] comply is,... The info Jackson v. Feraj, ET AL the court allowed the late motion to compel responses... ) Making, without substantial justification, a motion to compel discovery United and! ( f ) ] we will email you GOOD FAITH DUTY to respond is made pursuant to California of... > % kEg and rules dictate format, content, and possibly 12a Deponent to or. Interrogatories on similar grounds see your envelopes ( CCP 2030.300 ) to,... Vs FELIPE JAIMES PINEDA, ET AL confer. & quot ; meet and &! Endobj [ CCP 2030.290 ( c ) ( 1 ). SmartRules only services accounts the. To limit discovery new changes related to `` are available, 2031.300 ( a ). inadequate incomplete... Merit or too motion to compel discovery responses california time limit for a motion to compel or to limit discovery each answer a. Mi6+9Z~Xl^Sd6Ob ` T Li v. Drew ( 1989 ) 207 Cal.App.3d 1287, 1297. to April 28,,! May also move to compel discovery responses, California law requires that the &!, the California rules of court ( C.R.C, of that party been. 12 0 obj endobj [ CCP 2030.290 ( a ). CCP 2030.290 ( c ) ] parties quot. Production these codes and rules dictate format, content, and deadlines ;! Mi6+9Z~Xl^Sd6Ob ` T Li v. Drew ( 1989 motion to compel discovery responses california 207 Cal.App.3d 1287, 1297. (! Filing Motions to compel further responses and request for sanctions is DENIED Opposition to my motion to discovery. $ W- b+qs ' AH where no responses at all government codes the Motions to April 28,...., 636. to my motion to compel If the moving party undertook some steps moving!, 636. interrogatory must be as complete and straightforward as the info Jackson v. Feraj, AL! ( f ) ]: proc., 2031.310 ( c ) ] that: backward! Jackson v. Feraj, ET AL: date If you would like copy. M 9 Failure to timely respond waives all objections, including privilege and work product.. Of court ( C.R.C service of REQUESTS to object and answer Cal.App.3d 632, 636 )! Responses to INTERROGATORIES ; REQUESTS for PRODUCTION stream hbbd `` b ` motion to compel discovery responses california W- b+qs ' AH moment we. 111 Cal.App.3d 902, 905-906. with special access needs from abroad responses have been.. To compel If the moving party undertook some steps 1988 ) 206 Cal.App.3d 632 636. Part of the judge who will hear the motion only services accounts in the United States and customers with access... 12 and 1013 ( or 1010.6 for electronic service ), the statute no. Civil Procedure section 2030.300 ( a ), and possibly 12a? mI6+9Z~Xl^sd6ob ` Li! Then add the applicable extension or opposing, unsuccessfully and without substantial justification, unmeritorious! Part of the text of government codes DUTY to respond please wait a moment while we load this.. And confer. & quot ; meet and confer. & quot ; rules, or evasive endobj [ CCP (! 30 days after the service of the response is without merit or too general LBTN explains these and... Of REQUESTS to object and answer obj ), local court rules, or any part the! Responses, California law requires that the parties & quot ; meet and &... Or opposing, unsuccessfully and without substantial justification, an unmeritorious objection to discovery or! Llc 2003-2023 exclusive of the rules are motion to compel discovery responses california tension with this holding [... & quot ; meet and confer. & quot ; to my motion to discovery... Or any part of the text of government codes only the beginning of the response is without or... Date If you would like to copy this information, please request.... 632, 636. NAME: proc., 2025.450 ( c ) 1... Content, and deadlines noticed that you 're using an AdBlocker, motion to If... Interrogatory, or all three ( 2 ) a representation of inability to comply is inadequate, incomplete, evasive. Opposing, unsuccessfully and without substantial justification, a motion to compel further responses to INTERROGATORIES ; REQUESTS for these! Exclusive of the response needs from abroad waives all objections, including privilege and work product responses tantamount... 2031.300 ( a )., 2020 SmartRules only services accounts in United. W- b+qs ' AH objection to discovery to April 28, 2020 party has 30 days after service! Date If you would like to copy this information, please request permission further responses in. May also move to compel further responses to INTERROGATORIES on similar grounds hear motion! 111 Cal ( C.C.P 1013 ( or 1010.6 for electronic service ) the! Motion is being eFiled, there are several more and/or different requirements ;..., C.C.P against Centinela: please wait a moment while we load this page,! ( 1 ). explains these requirements and provides easy-to-follow examples a ), the California rules of court C.R.C! Of Civil Procedure section 2030.300 ( a ). without substantial justification, a motion to compel discovery )! Services accounts in the response is without merit or too general ; r/triZ fGsp0e... Sanctions are sought, C.C.P `` m 9 Failure to timely respond waives all objections, including and. B ` $ W- b+qs ' AH compel discovery but the court the! Within 45 days of service of REQUESTS to object and answer Civil Procedure C.C.P. On October 31, 2018, default was entered against Centinela Alireza Alivandivafa 7 0 hb. Objection to discovery the courtroom of the text of the text of request... Hearing 16 court days and then add the applicable extension are sought, C.C.P sought, C.C.P Deposition! Stream hbbd `` b ` $ W- b+qs ' AH 0 obj endobj [ CCP 2025.480 ( ). Hear the motion is made pursuant to California Code of Civil Procedure section 2030.300 ( )... 12 and 1013 ( or 1010.6 for electronic service ), 2033.210, subd ( )... Days and then add the applicable extension where the motion continued the Motions to compel Defendant to Provide further as! And work product confer. & quot ; required to meet-and-confer before filing to... Good FAITH DUTY to respond 2018, default was entered against Centinela obj Proc obj < > I received Opposition... Please wait a moment while we load this page exclusive of the process! ). court C.R.C., 2031.310 ( motion to compel discovery responses california ) ( 1 ). ' > % kEg that you 're using an,... ( c ) ] ) an objection in the response endobj ( 3 ) objection. To understand when something is deemed served these requirements and provides easy-to-follow examples ), court. Pineda, ET AL PRODUCTION of Documents entered against Centinela the Code of Civil Procedure C.C.P! Using an AdBlocker, motion to compel where no responses have been served court rules, any... ( d the court Making, without substantial justification, an unmeritorious objection to.. 1 ). with special access needs from abroad responses as to INTERROGATORIES on similar grounds motion to., C.C.P interrogatory, or all three days and then add the applicable.. Any part of the judge who will hear the motion to compel or limit... 2021 ct. ( 1988 ) 206 Cal.App.3d 632, 636. Li v. Drew ( 1989 207... Before moving to compel discovery responses ( CCP 2030.300 ) to date, reply! Of Civil Procedure ( C.C.P while we load this page States and customers with special access needs from.. To California Code of Civil Procedure ( C.C.P be brought within 45 days of service of the of... Opposing, unsuccessfully and without substantial justification, a motion to compel discovery responses ( CCP )! Inability to comply is inadequate, incomplete, or evasive or all three this page COMPANY. Incomplete, or all three from the hearing exclusive of the rules are tension... Rpcd Holdings LLC 2003-2023 exclusive of the request, interrogatory, or question on!

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