We are in the era of pandemic and stay at home orders; an era where the lack of uniformity within our court system is giving defendants the upper hand. But don’t despair! This webinar will teach you how to use motions to compel and protective orders to stop defense’s games.

This webinar will discuss when to move to compel discovery responses, the type of motion to compel you should file, and when you should or shouldn’t agree to a protective order. Stay aware of defense’s predictable games and their abusive discovery tactics by learning an aggressive forward-thinking approach to litigation.

MOTIONS TO COMPEL: overview - basic idea of discovery and what you need

• Importance of tailor-made discovery
• Know your judge
• Meet and confer
• What is a proper response to discovery from the defense?
• When do you compel responses?
  • Procedures to follow to get the judge to agree with you on a motion to compel
  • Pictures and diagrams to help judges understand
  • Arguing style
• Getting judges to award sanctions.

MOTIONS TO COMPEL: Topic Specific

• Document Production Requirements: CCP 2031.280(a)
• Types of Motions to Compel You need to File
  • Insurance Coverage
  • Incident Reports and Witness Statements
  • Sub Rosa
  • Repair records
  • Depositions
• Motions to Quash
  • Medical Records

PROTECTIVE ORDERS

• Whether or not to agree to one
  • Is it necessary?
  • Is it a shield?
• Case by case
  • When to refuse
  • When to agree
  •  How to protect your client's interests