Q: How to confront legally discovery harassment

A: I'm sorry to hear you're dealing with a frustrating and potentially harassing situation in the discovery process for your legal case. Here are a few thoughts on how to handle this under California law:

1. Meet and confer: California law requires parties to meet and confer in good faith to resolve discovery disputes before filing a motion to compel. Reach out to the defendant's counsel and try to work out a reasonable timeline for them to actually produce the witnesses for deposition, not just state that they "will produce" them at some indefinite future time. Explain that repeated rounds of non-responsive answers are causing unnecessary delay and expense.

2. Motion to compel: If the meet and confer is unsuccessful, you can file a motion to compel the depositions under the California Code of Civil Procedure. Argue that the defendant's stated intention to produce the witnesses at some unspecified future date, after multiple rounds of discovery, is evasive and fails to satisfy their discovery obligations. Ask the court to order the depositions by a firm deadline.

3. Sanctions: In your motion to compel, consider requesting monetary sanctions against the defendant under CCP Section 2023.010 for misuse of the discovery process. Argue that their repeated rounds of evasive responses and unfulfilled promises to produce amount to discovery abuse warranting sanctions.

4. Offer to narrow the witness list: If the defendant argues the requested depositions are overbroad or burdensome, consider offering to narrow the witness list to the most essential providers first, then revisit the need for additional ones later. A reasonable compromise may help convince the court your request is not harassing.

5. Protective order: If the dispute stems from confidentiality concerns, propose a protective order limiting the use of the deposition testimony to the case. This may alleviate some of the defendant's objections to producing the witnesses.

The key is to demonstrate to the court that you've tried to resolve this impasse reasonably, the requested depositions are material to your case, and the defendant's refusal to cooperate is baseless and harassing. Be professional in your communications and frame your requests as reasonable attempts to move the case forward.

I hope this general guidance is helpful for your situation. For more specific advice tailored to the details of your case, please consult with a qualified California civil litigation attorney. Wishing you the best in resolving this discovery dispute efficiently.