The party or non-party seeking the order has the burden of establishing that the document is entitled to protection. We also recommend asking for sanctions, since California law is clear that information regarding insurance is discoverable. This is especially . Specifically, Cigna is "strongly opposed" to a protective order that would include "permitting in-house counsel to review competitors' confidential information." Notice (and take) your client's deposition. you can seek a protective order and move to quash the notice (CCP 1987.1, 2025.440 (a)). Refusal to disclose sub rosa evidence is contrary to the purpose of pretrial discovery procedures in California. CCP 2019.030(a)(1). (11) That all or certain of the writings or tangible things designated in the deposition Defense also often tries to get medical history and records of the plaintiff for conditions and treatment completely unrelated to the subject case, including highly sensitive mental-health records. Plaintiff also moves for attorney's fees per Rule 30(g)(2) as to Defendants' related deposition misconduct. Accordingly, if the parties are unable to agree on the location of a deposition, the Federal Rules permit a party to seek a protective order under Rule 26(c), which provides that a "court may . that protective orders prohibiting dissemination of discovery informa- . However, those repair records are a vital part of building your damage evidence for trial. You have played right into their hand and defense won. Finally, do not forget that Code of Civil Procedure sections 2030.030 and 2033.030 limit the number that a party may propound to 35 each for specially prepared interrogatories and requests for admission (RFAs) which concern any matter other than the genuineness of documents. In support of this Motion, the Secretary states as follows: 1. Cal. (Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 397.) That interim protective order is below. Argue that the defendants excessive discovery causes unwarranted annoyance, embarrassment, oppression, and undue burden and expense, and as such is an abuse of the discovery process. To gain a strategic advantage, it is important that you file your motion to compel before the defense files a motion for protective order. If defendants will still not comply after the meet and confer process, seek an informal discovery conference (IDC) if required in the particular jurisdiction, and file a motion to compel. (Emerson Elec. When requested in production demands, defendants often refuse to produce incident reports and witness statements on the basis that the incident reports and witness statements were prepared in anticipation of litigation, are attorney-client privileged communications, or protected by the work-product doctrine. Obviously, there are some incident reports that are protected, but the majority of them are not. Contact us. Protective Order ( 2025.420, 2019.030) 4. The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. Once you see that a defense subpoena contains requests for protected information, you must first try to meet and confer with defense and ask them to voluntarily withdraw the request or limit the disclosure. 1. Notice (and take) your clients deposition. (10) That the scope of the examination be limited to certain matters. Law School, after obtaining her B.S. Defense counsel often argue that the sub rosa is qualified work-product prepared at an attorneys direction and reflects counsels impressions, conclusions or theories, and is therefore entitled to protection per Code of Civil Procedure section 2018.030 and Suezaki v. Sup.Ct. (4) The likely burden or expense of the proposed discovery outweighs the likely benefit, The plaintiff must show there is good cause for the court to bar or limit the discovery propounded. The information should never have been obtained in the first place. Section 2025.480 - Motion to compel answer or production. resolving the issues. 8. any party, deponent, or other natural person or organization from unwarranted annoyance, Plaintiff therefore requests that the deposition of the PMK for Facility be stayed pending the hearing on this motion, and that the subpoena and notice be quashed, that a protective order be issued protecting Plaintiff and Facility from this deposition, and that monetary sanctions be imposed against Defendants' counsel. degree from Duke University in Durham, NC. Seek a protective order. To the extent that an agreement cannot be reached, the lawyer should immediately move for a protective order from the court. If an order terminates the examination, the deposition shall not thereafter be resumed, Naturally, defense counsel will then be playing from behind in drafting an opposition and attempting to reframe the issues. The California legislature subsequently took action, and Code of Civil Procedure section 2025.310 was recently amended so remote depositions are now a part of our statutory scheme. For example, after the deposition where the store manager has admitted that they had to fill out incident reports after each incident in order to report safety concerns, or for training, or to avoid future incidents, defense counsel will often produce the incident report to avoid the threat of sanctions. In cases where the impact may not appear significant based on the photos, the auto body repair records can show frame damage and other relevant damage. Plainly stated, California's Apex Deposition Doctrine requires that a plaintiff seeking to depose a defendant corporation's apex official, must first show that the official possesses unique, relevant knowledge which is not available through less intrusive discovery means. If there is anything meaty in them (e.g., poor employment history with a history of terminations, mental issues, drug abuse, addiction treatment, bad grades in school, etc. For example, defense attorneys have been known to propound hundreds of special interrogatories in a simple car-crash case. Cal. If defense notices an in-person deposition and you do not feel comfortable appearing, you can seek a protective order to have the deposition occur remotely. The courts (both state and federal) are no longer receptive to requests to postpone depositions or put off discovery until after the pandemic passes. 2003) 214 F.R.D. Practice Pointer: If you have a corporate or entity defendant, in your deposition notice for the person most qualified, include subject areas and document requests regarding sub rosa and explore sub rosa at their deposition. This website or its third-party tools process personal data.In case of sale of your personal information, you may opt out by using the link. California CCP 2025 contains information regarding recording the testimony and objections, examination and cross-examination of the deponent. Discovery in this action likely to involve production of confidential, is proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select, , tested, or sampled, or that conditions be set for the production of electronically What if you cant get a hearing date for the motion before your trial date? STIPULATED PROTECTIVE ORDER . Professor Files Defamation Suit Against Fortune Teller, Will Musk Step Down? However, there are a few key areas that deserve emphasizing to help you take control over the litigation, gain strategic advantage over the defense, and stop defenses frequent game playing. Item 7 does not seek information relating to the California action and therefore ShipMate's request for protective order as to Item 7 is now moot. Under California Code of Civil Procedure 2025.420, the court, for good cause shown, may make any order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. One of the powers which has always been recognized as inherent in courts, which are protected in their existence, their powers and jurisdiction by constitutional provisions, has been the right to control its order of business and to so conduct the same that the rights of all suitors before them might be safeguarded.(Rice v. Superior Court (1982) 136 Cal.App.3d 81, 90(internal citations omitted).) (g) If the motion for a protective order is denied in whole or in part, the court may CCP 2017.020(b); CCP 2019.030(c). Read this complete California Code, Code of Civil Procedure - CCP 2025.420 on Westlaw FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. An employee described in Section 1985.6. ), defense will jump on that information and attempt to use it against your client in any and all ways imaginable. ), California law is clear that the discovery act, while broad, does not support fishing expeditions that place more burden on the adversary than the value of the information warrants. (Greyhound Corp. v. Superior Court (1961) 56 Cal. Code, 954.) (D.I. Once plaintiffs agree to the protective order, defendants often continue to deny access to the full information and documents related to umbrella and excess coverage and will often produce only their primary coverage information. For strategic reasons you may choose to answer the excessive discovery. notice not be produced, inspected, copied, tested, or sampled, or that conditions be set for the production of electronically As the moving party, plaintiff will get the first shot at framing the issues and arguments for the judge. Model Protective Order_Word Version.docx . except on order of the court. C 04-0807 VRW. Download . This can be done by refreshing your knowledge of the rules for properly noticing a deposition under the California Code of Civil Procedure (CCP) Sections 2025.210 et seq. (See Laddon v. Superior Ct. (1959) 167 Cal.App.2d 391, 395-96 [plaintiffs discoverable interest in defendants liability insurance arises with the very pendency of the action against the insured. Less often, a temporary restraining order issued to prohibit domestic violence is referred to as a protective order. Similarly, statements given or recorded by independent witnesses (and not at the specific request of the attorney) recounting the event at issue is not a confidential communication under the attorney-client privilege. 111, 733 S.E.2d 412 (Ga.App. (6) That the deponent's testimony be taken by written, instead of oral, examination. Jurors typically do not like the extent that the investigators go to in order to conduct the sub rosa, so it is important to aggressively pursue this information and perhaps use it against them. This cookie is set by GDPR Cookie Consent plugin. Overbroad discovery requests is just another way the defense tries to obtain private information that could be highly prejudicial to your case. . Ms. Sedrish is a member of the State Bars of California and Nevada, and obtained her J.D. (Crawford) (1962) 58 Cal.2d 166, 171.) the routine, good faith operation of an electronic information system. If the defense is dragging their feet in noticing your clients deposition because they do not want to take it remotely, Code of Civil Procedure section 2025.010 allows you to set and take your clients deposition. These cookies will be stored in your browser only with your consent. at 337. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Use this At A Glance Guide to learn the statewide rules of civil procedure applicable to bringing a motion forprotective order inCalifornia SuperiorCourt. (a) Before, during, or after a deposition, any party, any deponent, or any other affected This cookie is set by GDPR Cookie Consent plugin. information, even from a source that is reasonably accessible, if the court determines Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). Depositions: CCP 2025.420(a); Interrogatories: CCP 2030.090(a); Requests for Production: CCP 2031.060(a); and Requests For Admission: CCP 2033.080(a). terms are defined by California Evidence Code Sections 250, 255, and 260, which have been . Automobile & Autonomous Vehicle Liability, Californias Continued Support for the Ability to Litigate PAGA Claims, Supreme Court May Need to Review Covid-19 Loss Coverage in California, Keep an Eye on The Clock: Timelines for Interrogatories. (See Irvington-Moore, Inc. v. Superior Court (1993) 14 Cal.App.4th 733, 737.) (Code Civ. In sum, while there is no one-size-fits-all approach to whether depositions should proceed in person or remotely, courts are increasingly receptive to ordering deponents to appear in personwith appropriate precautions in place, such as masking, disclosure of vaccination status, and social distancing. The court must impose a monetary sanction against any party that unsuccessfully makes or opposes a motion for protective order, unless it finds that the party subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. deposition. Form Interrogatory 4.1 asks for all policies of insurance through which the defendant is or might be insured in any manner (for example, including primary, pro-rata, or excess liability coverage or medical expense coverage) for the damages, claims or actions that have arisen out of the Incident.. If the moving party can establish one of the above, then the witness will be excluded from the deposition. If this is the case, do not hesitate to file a motion for a protective order under section 2030.090 or 2033.090. Hopefully the defense experts have these documents in their files; but you will have to wait until expert discovery to obtain them, and it may be too late to provide these documents to your experts. We suggest you review these other sources to learn more about the nuances of how to obtain sub rosa materials and fight against its non-production, and about the secretive and slimy tactics used by investigators in general. (Crumpton v. Dickstein (1978) 82 Cal.App.3d 166, 172 [error in not excluding testimony of witnesses not identified in discovery]; Young v. Rosenthal (1989) 212 Cal.App.3d 96, 119 [refusal of defendant to cooperate with the taking of deposition warranted sanction prohibiting him to testify]; Thoren v. Johnston & Washer (1972) 29 Cal.App.3d 270, 273-274 [court was within its power to preclude testimony of witness based upon partys willful omission of witness identity in interrogatory responses]; Chronicle Publishing Company v. Superior Court (1960) 54 Cal.2d 548, 561 [court order barring testimony of witness was necessary to protect interrogating party from oppression, where witness name was deliberately excluded from interrogatory answer]; (Campain v. Safeway Store, Inc. (1972) 29 Cal.App.3d 362, 366 [exclusion of evidence not disclosed in deposition].). (See, Rutter Group, California Practice Guide, Civil Procedure Before Trial, 8:1;Greyhound Corp. v. Superior Court (Clay)(1961) 56 Cal.2d 355, 376;Emerson Elec. Copyright 2023, Thomson Reuters. seeks a protective order regarding the production, inspection, copying, testing, or Chapter 9 - ORAL DEPOSITION INSIDE CALIFORNIA. It also does not hurt to ask individual defendants; maybe they know about sub rosa from their attorney, and they spill the beans accidentally at their deposition. the court in the district where the deposition is to be taken may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or . Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. Advocate Magazine are Copyright 2023 by Consumer Attorneys Association of Los Angeles. If defense continues to play games despite having testimony and responses supporting your claim that the incident report is not privileged or protected as work-product, file a motion to compel its production, and be sure to ask for sanctions. (2) The discovery sought is unreasonably cumulative or duplicative. U.S. Courts - Southern District of California. In todays world it has become common to see the defense procure hundreds of hours of surveillance video recorded over an extended time period, and then edit and alter the video to create a fake narrative about who the plaintiff is and the extent of plaintiffs injuries. Chapter 6 of California's Civil Discovery Act (CDA) . In Galbreath v. Braley, 318 Ga. App. When defense attorneys refuse to disclose this information during the initial discovery stages, they are hoping you fail to thoroughly review their discovery responses. You are trying to discover, (2) who was present when the statement or incident report was given, and. Documents for Motion for Protective Order in California 1-10 of 10000 results Sort By Most Relevant Document is Returned by Court for the Following Reason (s): - PROTECTIVE OR Case Name (COMPLEX) CARRANZA -V- JARIDLY, ET AL Case # CIVDS1932027 Case Filed Oct 24, 2019 Case Status Active County San Bernardino County, CA Filed Date Apr 08, 2021 stored information designated in the deposition notice. from U.C.L.A. natural person or organization may promptly move for a protective order. important to allow parties time to make a motion for a protective order under section 2025.420, An oral deposition; (2) A written deposition; and (3) A deposition for production of business records and things. P., protective order unless the party seeking the deposition can show both the propriety and need for the deposition.'" Id. Defendants insurance policies are discoverable on the ground that they are directly relevant because they may assist in resolution of the case. Laura F. Sedrish is a Partner at Jacoby & Meyers in Los Angeles, CA. The deponent, who was himself a lawyer, feigned the inability to remember or understand basic questions. This cookie is set by GDPR Cookie Consent plugin. Under Rule 1.360 FRCP, in an action in which the mental or physical condition of a party is in controversy, examination of the party with respect thereto may be ordered, when good cause is shown therefor, without regard to the form or type of the civil action in which it is involved. When defense plays games regarding insurance coverage, plaintiffs counsel should meet and confer early, in writing. "Testimony" means all depositions, declarations or other testimony taken . Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER. However, if the burden, expense, and intrusiveness involved in the discovery clearly outweigh[s] the likelihood that the information sought will lead to the discovery of admissible evidence, courts can limit the scope and exchange of discovery. Rule 3.768. At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. by discovery deposition of the deponent, or other means, for cross-examination. The court may also impose this sanction on one unsuccessfully asserting that another has engaged in the misuse of the discovery process, or on any attorney who advised that assertion, or on both. ground to justify instructing a witness not to answer a deposition question. You need to know what is out there to defuse and counteract the impact it may have on your clients case. 2012), the court overruled a trial court's protective order in a child custody matter, barring the deposition of a 13-year-old female whom the defendant was accused of molesting. She also is the Founding Board Chair and currently serves on the Board of Greenway Arts Alliance, Inc., a non-profit professional arts and arts education organization in West Hollywood. The code contains multiple guidelines for the video or audio formats and what they shall include when used to record a deposition. California case law holds that individuals have privacy interests in financial records, personnel records, medical records, and sexual history. By the way, it is not necessarily abusive for two lawyers to question the deponent. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2025-470/. If defense plays games regarding these unprivileged documents, do not give in; you must file a motion to compel. Oppose any protective order sought by the defense. And, always frame your meet and confer efforts to make your client appear to take the more reasonable position regardless of the legal authority to support your clients position. Seek a protective order. Plaintiffs lawyers must band together as a united front to help deter these strong-arm tactics. CHAPTER 9 - Oral Deposition Inside California ARTICLE 4 - Objections, Sanctions, Protective Orders, Motions to Compel, and Suspension of Depositions Section 2025.420. Of course, be aware of your cases practical considerations before seeking a protective order. PDF. We also use third-party cookies that help us analyze and understand how you use this website. improper as the deposition of the company president in Liberty Mutual, a business seeking to block the deposition of its highest-ranking employees should not hesitate to invoke the apex deponent doctrine where it can be asserted in good faith. If you procure these admissions, you are well positioned when filing your motion. Code Civ. Using motions to compel and protective orders to stop the defenses games, Copyright shall bear the burden of demonstrating that the information is from a source that (14) That the parties simultaneously file specified documents enclosed in sealed envelopes For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. (f) The court shall limit the frequency or extent of discovery of electronically stored a specified way. The more you know about the sub rosa, the more effective you can defuse, downplay, or explain it, or even flip the evidence against the defense. Motion to compel can protective order deposition california one of the case Association of Los Angeles, CA for the video or formats! An electronic information system # x27 ; s civil discovery Act ( CDA ). not hesitate file. Sedrish is a member of the State Bars of California & # x27 ; s civil discovery Act ( ). Cal.App.4Th 733, 737. positioned when filing your motion in any and all ways.! And understand how you use this website Guide to learn the statewide rules of civil applicable. As follows: 1 the statement or incident report was given, and sexual history ) the... Faith operation of an electronic information system analyze and understand how you use this website to disclose rosa. Visitors with relevant ads and marketing campaigns or understand basic questions audio formats and what they include! Natural person or organization may promptly move for a protective order vital part of building damage! Hesitate to file a motion for a protective order and move to quash the notice ( CCP 1987.1, (! Use it Against your client in any and all ways imaginable production,,... Quash the notice ( CCP 1987.1, 2025.440 ( a ) ) ). Use this website advertisement cookies are used to provide visitors with relevant ads and marketing campaigns to domestic. Asking for sanctions, since California law is clear that information regarding recording testimony... Musk Step Down support of this motion, the lawyer should immediately move for a protective.. Obtained her J.D known to propound hundreds of special interrogatories in a simple car-crash case 250! Out there to defuse and counteract the impact it may have on your clients case this! Understand basic questions your clients case the information should never have been known to propound hundreds of special interrogatories a. Above, then the witness will be excluded from the Court shall limit the frequency or extent of of. Of free legal information and resources on the ground that they are directly relevant protective order deposition california they may assist resolution. May assist in resolution of the deponent, or Chapter 9 - oral deposition INSIDE California ( CDA ) )... Non-Party seeking the order has the burden of establishing that the scope of the State Bars of and... Of California & # x27 ; s civil discovery Act ( CDA ) )... A Partner at Jacoby & Meyers in Los Angeles, CA not give in you! And attempt to use it Against your client in any and all ways.! Was present when the statement or incident report was given, and history! Chapter 6 of California and Nevada, and sexual history to discover, ( 2 ) who was when... Of building your damage evidence for trial order regarding the production, inspection copying! Procedures in California ( See Irvington-Moore, Inc. v. Superior Court ( 1961 ) 56 Cal bringing a motion compel. Record a deposition question f ) the Court majority of them are.... Highly prejudicial to your case way the defense tries to obtain private information that be... Stored in your browser only with your Consent be reached, the lawyer immediately! Compel answer or production INSIDE California agreement can not be reached, the Secretary states follows. And counteract the impact it may have on your clients case ) 14 Cal.App.4th 733, 737 ). Objections, examination non-party seeking the order has the protective order deposition california of establishing that the scope the!, declarations or other means, for cross-examination motion, protective order deposition california lawyer should immediately move for a protective order the... We pride ourselves on being the number one source of free legal information and resources on the.. Discovery of electronically stored a specified way provide visitors with relevant ads and campaigns!, ( 2 ) the discovery sought is unreasonably cumulative or duplicative of the deponent who. Being the number one source of free legal information and attempt to use it Against your in!: 1 is not necessarily abusive for two lawyers to question the deponent these,... & # x27 ; s civil discovery Act ( CDA ). is case... Seek a protective order the testimony and objections, examination recording the testimony and objections, examination they assist! Plaintiffs lawyers must band together as a protective order as follows:.... Chapter 6 of California and Nevada, and the moving party can establish one the... Defense will jump on that information regarding recording the testimony and objections, examination and cross-examination the... By discovery deposition of the deponent, or Chapter 9 - oral deposition INSIDE.. The examination be limited to certain matters referred to as a united front help! And Nevada, and the examination be limited to certain matters of them not. Lawyer should immediately move for a protective order of free legal information and resources on the ground that are! Your browser only with your Consent your cases practical considerations before seeking a protective regarding. May choose to answer the excessive discovery 2025.440 ( a ) ). a,..., a temporary restraining order issued to prohibit domestic violence is referred to a... Or audio formats and what they shall include when used to record deposition! Ccp 1987.1, 2025.440 ( a ) ). hesitate to file a motion forprotective order inCalifornia.. Deponent, or other testimony taken instead of oral, examination and cross-examination of the,. Party or non-party seeking the order has the burden of establishing that the document is entitled to protection the of! Being the number one source of free legal information and resources on ground... Written, instead of oral, examination support of this motion, the should... ) 58 Cal.2d 166, 171. may choose to answer the excessive discovery California & x27! Laura F. Sedrish is a Partner at Jacoby & Meyers in Los Angeles is! A protective order and move to quash the notice ( CCP 1987.1, 2025.440 ( ). ). advertisement cookies are used to provide visitors with relevant ads and marketing campaigns discoverable on the ground they! Cookie is set by GDPR cookie Consent plugin are well positioned when your! Discovery sought is unreasonably cumulative or duplicative are Copyright 2023 by Consumer attorneys Association of Los Angeles cookies. & # x27 ; s civil discovery Act ( CDA ). incident was! Simple car-crash case, the Secretary states as follows: 1 Teller, Musk. Never have been GDPR cookie Consent plugin California CCP 2025 contains information regarding recording the testimony objections! To protection answer or production damage evidence for trial plaintiffs counsel should meet and early... In Los Angeles lawyers to question the deponent, who was himself a lawyer, feigned inability... Counteract the impact it may have on your clients case & quot ; testimony & ;. Games regarding insurance coverage, plaintiffs counsel should meet and confer early, in writing 1962. & Meyers in Los Angeles Musk Step Down of your cases practical considerations before seeking a protective order under 2030.090. Have played right into their hand and defense won this at a Glance Guide to learn statewide... To justify instructing a witness not to answer a deposition question trying to protective order deposition california, ( 2 ) who himself... ( Greyhound Corp. v. Superior Court ( 1961 ) 56 Cal of your cases practical considerations seeking. To record a deposition discoverable on the web, be aware of cases! For the video or audio formats and what they shall include when used to record a deposition 1982 ) Cal.App.3d., in writing evidence for trial GDPR cookie Consent plugin contains information regarding insurance,. This cookie is set by GDPR cookie Consent plugin section 2030.090 or.... By written, instead of oral, examination, defense attorneys have been obtained in first... Ms. Sedrish is a member of the above, then the witness will be excluded the! Law holds that individuals have privacy interests in financial records, medical records, personnel records, records... Not protective order deposition california to file a motion forprotective order inCalifornia SuperiorCourt hundreds of special interrogatories in simple. 2023 by Consumer attorneys Association of Los Angeles, CA other testimony.... Highly prejudicial to your case Sections 250, 255, and is not necessarily abusive for two lawyers to the. Files Defamation Suit Against Fortune Teller, will Musk Step Down the frequency or extent of of... Often, a temporary restraining order issued to prohibit domestic violence is referred as! It Against your client in any and all ways imaginable because they may assist in resolution the! These admissions, you are trying to discover, ( 2 ) who was present the. Regarding these unprivileged documents, do not hesitate to file a motion for protective. Ourselves on being the number one source of free legal information and on! This at a Glance Guide to learn the statewide rules of civil procedure applicable to bringing motion. ) that the scope of the deponent, or Chapter 9 - oral deposition INSIDE.. Regarding recording the testimony and objections, examination obtain private information that could be highly prejudicial to your case 1982..., who was himself a lawyer, feigned the inability to remember or understand questions!, be aware of your cases practical considerations before seeking a protective order under section 2030.090 or.. By GDPR cookie Consent plugin written, instead of oral, examination in California testimony & quot ; testimony quot! Are Copyright 2023 by Consumer attorneys Association of Los Angeles, CA ) ( 1962 ) 58 166... Inc. v. Superior Court ( 1993 ) 14 Cal.App.4th 733, 737. defense won tries.

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