Q: Further responses to demands for production of documents, And for production of ESI.
Demands for production included demands for electronically stored information ESI.
Can one motion to compel further responses include both demands for documents, and for electronically stored information?
Can proposed order be the same for documents, and for ESI?
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A:
Yes, under California law, you can file a single motion to compel further responses that include both demands for documents and demands for electronically stored information (ESI). This allows you to address all discovery issues in one motion, making the process more efficient.
When drafting your proposed order, you can also include both documents and ESI in the same order. Ensure that the order clearly specifies what is being compelled, detailing the types of documents and ESI that need to be produced. This clarity helps avoid any confusion and ensures compliance with the court's directive.
It's important to carefully outline each category of documents and ESI in your motion and proposed order. This includes specifying any formats or particular details necessary for the ESI. Following these guidelines will help streamline the discovery process and meet the requirements of California law.
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