by Judge Owen Lee Kwong, Donald G. Rez, and Robert F. Kane

Forms and Procedure for
California Litigation

Authors Robert F. Kane and Donald G. Rez share their wisdom and documents in this sophisticated and affordable procedure guide. 3,600 cases and 175 forms, advice from the bench, case-based illustrations, practice-proven strategies, step-by-step procedures, pattern language, and a full-text CD, support the 1,475 pages of text. Coverage runs from taking the case up to trial, and includes numerous tips on how to: avoid and fix mistakes, resolve peripheral disputes, craft better documents, answer ethical questions, process cases efficiently, and sharpen your responses.

California Pretrial Practice & Forms focuses on areas where questions frequently arise. Half of the book’s pages address pleadings, motions, and discovery. Six chapters are devoted to discovery issues and procedures. You will find detailed coverage of:

Pleadings
Summons & service
Dealing with insurers
Jurisdiction & venue
Motion practice
Summary judgment
TROs & injunctions
Defaults
Privileges
Production of documents
Physical & mental exams
Interrogatories
Depositions
Requests for admissions
Discovery disputes
Settlement & ADR

Focused on Issues

California Pretrial Practice & Forms concentrates on the topics where questions and disputes arise. It devotes pages where you spend time: drafting pleadings, preparing and presenting motions, conducting discovery, resolving discovery disputes, and negotiating settlements. For example, you will find coverage of troublesome matters like:

Depositions

Common traps for the examiner. §22:362
How to block coaching. §22:366
A trick for obtaining deposition notes. §22:367
What are the procedures for subpoenaing a non-party witness for deposition? §22:190
When is it appropriate and not appropriate to suspend a deposition? §22:380
What should examining counsel do when a witness refuses to answer questions at deposition? §22:368
When representing a deposition witness, when should I instruct the deponent not to answer a question or produce a document? §22:510
What objections are proper during a deposition? §22:550
Objecting vs. filing a motion to quash. §22:465

Document Discovery

Dealing with document discovery disputes. §21:350
Discovery of personal and employment records. §21:540
Moving for a protective order, and when it is likely to be granted. §22:471
Strategic considerations when confidential information is sought. §20:34
Extending time to answer with objections. §21:145
Which objections to a notice to produce are likely to stand up? §21:260
What are the best grounds and tactics for withholding documents from production? §21:260

Motions

Strategic considerations. §14:10
Practical advice on pagination, titling, parties' names, etc. §14:20
Brief-drafting tips. §14:150
Tips from the bench for effective oral argument. §14:430
Grounds for ex parte motions. §14:490
Tactical considerations for opposing motions. §14:310

California Pretrial Practice & Forms delivers quick and reliable answers with its outline format, tight writing, superb scholarship, and extensive citations. Its practice-tested forms and pattern paragraphs speed drafting. And the accompanying full-text CD-ROM, containing the entire book text, plus over 175 modifiable forms, provides a second and portable reference at no extra charge. The text is boolean searchable, and every word and citation is linked.

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