Excerpt: ...eglect.” “Section 473 is often applied liberally where the party in default moves promptly to seek relief, and the party opposing the motion will not suffer prejudice if relief is granted. [Citation.] In such situations ‘very slight evidence will be required to justify a court in setting aside thre default.' [Citation.]” (Elston v. City of Turlock (1985) 38 Cal.3d 227, 233; see also, Fasuyi v. Permatex, Inc. (Fasuyi) (2008) 167 Cal.App.4 ...

Excerpt: ...es, “(a) If a deponent fails to . . . produce any document, electronically stored information, or tangible thing under the deponent's control that is specified in . . . a deposition subpoena, the party seeking discovery may move the court for an order compelling that . . . production. [¶] (b) The motion shall be made no later than 60 days after the completion of the record of the deposition, and shall be accompanied by a meet and confer declar...

Excerpt: ...ng party may move for an order compelling a further response if the propounding party deems that any of the following apply: [¶] (1) An answer to a particular interrogatory is evasive or incomplete . . . [¶] (3) An objection to an interrogatory is without merit or too general.” Code of Civil Procedure section 2030.220, provides, “(a) Each answer in a response to interrogatories shall be as complete and straight forward as the information re...

Excerpt: ...essional Conduct, rule 3-700, subdivisions (C)(1)(d) and (C)(1)(f). Moving Counsel will remain the attorney of record for Air802, LLC until Moving Counsel files proof of service of the signed order upon Air802, LLC. The order will become effective upon the filing of the proof of service upon Air802, LLC. Moving counsel to give notice. Moving Counsel's (Law Offices of Thomas F. Nowland) unopposed Motion to be Relieved as Counsel for Defendant—Mi...

Excerpt: ...his litigation and prepare the case for trial. Client has also failed to assist counsel in the litigation and there is currently a breakdown of the attorney-client relationship.” The declaration submitted in support of this Motion supports withdrawal under Rules of Professional Conduct, rule 3-700, subdivisions (C)(1)(d) and (C)(1)(f). Moving Counsel will remain the attorney of record for Mr. Lee until Moving Counsel files proof of service of t...

Excerpt: ...s or her burden of showing that a cause of action has no merit if that party has shown that one or more elements of the cause of action, even if not separately pleaded, cannot be established, or that there is a complete defense to that cause of action. Once the defendant . . . has met that burden, the burden shifts to the plaintiff . . . to show that a triable issue of one or more material facts exists as to that cause of action or a defense ther...

Excerpt: .... . . .” Code of Civil Procedure section 576 provides, “Any judge, at any time before or after the commencement of trial, in the furtherance of justice, and upon such terms as may be proper, may allow the amendment of any pleading . . . .” “A court, at any time before or after commencement of trial, may allow an amendment to a pleading in furtherance of justice. [Citation.] Where no prejudice is shown to the adverse party, the liberal rul...