Excerpt: ...mplaint and cross-complaints. To the extent the declaration is based on information and belief, and not personal knowledge, it is inadequate to support the argument that severance for discovery and trial is needed to reduce the prejudice, delay and unnecessary expense to NSP3 (and Borga Steel) while at the same time not causing undue prejudice to the remaining parties. (Pelayo v JJ Lee Management Co Inc (2009) 174 Cal.App.4 th 484, 494 [key is if...

Excerpt: ... requiring electronic documents to be identified with respect to the request number, does not apply to the discovery motion presently before the court. The court agrees with plaintiff that the requests to produce documents ##25-27 related to “why you failed to timely perform obligations” under the three project contracts were argumentative. The court finds that by producing all documents concerning delays due to “severe weather impacts” o...