Sample Opposition to Motion to Compel Further Responses to Documents for California

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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 § 2017.010, and on the further grounds that the requests for production of document are unduly burdensome and oppressive in that the particular documents requests are not specifically described and the categories are not particularized as required by California law, and that the moving party failed to make a reasonable effort to meet and confer.  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.  The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.