Legal means of California law, specific statutes and rules.

Question

What legal means, statutes and rules, California legislative mechanism provides to ensure that: 
1. Instead of depositions of unidentified persons in future, Defendant must respond to interrogatory with actual identity, personal information of individuals as defined by CCP 1798.3(a);  
And  
2. Provide proof that affiliation of those individuals with Defendant existed at times mentioned?

James L. Arrasmith · Answer

Under California law, there are several legal mechanisms available to ensure that a defendant identifies specific individuals and provides their personal information in response to interrogatories, as well as proof of their affiliation with the defendant at the relevant times: 
 
1. California Code of Civil Procedure (CCP) Section 2030.010 allows a party to propound interrogatories to another party, which may include requests for the identity and personal information of individuals. 
 
2. CCP Section 1798.3(a) defines "personal information" as any information that identifies, relates to, describes, or is capable of being associated with a particular individual, such as their name, address, telephone number, or email address. 
 
3. CCP Section 2030.220 requires the responding party to answer each interrogatory separately and fully in writing under oath, to the extent the information is known or available to the responding party. 
 
4. CCP Section 2030.250 allows the propounding party to move for an order compelling a further response if the initial response is deemed insufficient, evasive, or incomplete. 
 
5. CCP Section 2023.010 provides that misuses of the discovery process, including failing to respond or providing evasive responses to interrogatories, are subject to sanctions. 
 
6. California Evidence Code Section 1400 et seq. governs the authentication of writings, which may be used to establish the affiliation of individuals with the defendant at the relevant times. 
 
To ensure compliance, the propounding party may: 
 
1. Draft interrogatories that specifically request the identity and personal information of individuals, as well as proof of their affiliation with the defendant at the relevant times. 
 
2. Move to compel further responses under CCP Section 2030.250 if the defendant's initial responses are deemed insufficient or evasive. 
 
3. Seek sanctions under CCP Section 2023.010 for any misuse of the discovery process by the defendant. 
 
4. Demand that the defendant authenticate any documents or evidence provided to establish the affiliation of the identified individuals at the relevant times, in accordance with the California Evidence Code. 
 
By utilizing these legal mechanisms, a party can ensure that a defendant properly identifies individuals and provides their personal information in response to interrogatories, along with proof of their affiliation at the relevant times, in accordance with California law.

Q: Legal means of California law, specific statutes and rules.