Web468; Weil & Brown, California Practice Guide / Civil Procedure Before Trial, §§ 8:84-85.) 4.“Contention interrogatories cannot be used to require a layperson to provide answers to scientific matters on which expert testimony will be required at trial.” (Weil & Brown, California Practice Guide / Civil Procedure Before Trial, “Discov- WebDec 10, 2024 · Takeaways. Raise objections to the format of ESI clearly, with specificity, and within the timeframes set forth in Fed. R. Civ. P. 34 (b) (2) (A). Argue in your Motion to Compel that your opponent has waived all objections to your discovery demands by failing to timely and/or properly object to them.

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