Personal Injury Lawyer Blog
The following blog entry is written to illustrate a common motion filed during civil litigation. Reviewing this kind of filing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.
(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this insurance bad faith lawsuit and its proceedings.)
XYZ states in their motion there is no issue as to Mrs. Hall’s response. However, Mrs. Hall responded to the same questions as did Mr. Hall because they are joint plaintiffs and suffer the same loss and seek the same recovery. If XYZ had no issue as to Mrs. Hall’s response, then there is no as to Mr. Halls initial responses and supplemental responses. Ms. Hall provided information to the same form interrogatories that Mr. Hall responded.
Request for Production of Documents
In XYZ’s motion on page 2, line 11, they state plaintiffs did not respond at all (as to production of documents, then on line 12-14, state plaintiffs produced some documents (despite not responding to the document requests themselves), their production is obviously deficient. Again, XYZ states on page 3, line 24 to page 4, line 2, there was document production. As stated above plaintiffs faxed their pleaded responses to the production of documents on 12/08/08.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.
Plaintiffs do not have anything other than what was produced. This was stated in a telephone conversation to Mr. Butler on December 29, 2008, and in a subsequent letter to Ms. Lee. Plaintiffs have no other documents to produce other than older policies from Universal Street and other properties, and these were not requested. (See Part 3 of 6.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.