California Pretrial Practice & Forms

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.

Updated annually. ISBN 1-58012-089-X. Book price: $129.00

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Related Titles:

Federal Trial Evidence

Preparing a Case for Trial in Federal Court

Trial Evidence Foundations

Trial Objections

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