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1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

4 Any Attorney or Party

8 Superior Court of the State of California

9 For the County of _________________

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11 Any Plaintiff, ) Case No.


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12 Plaintiff, ) REQUEST FOR INFORMAL DISCOVERY
) CONFERENCE
13 vs. )
) DEPT:
14 Any Defendants, and DOES 1-5, inclusive, ) HEARING JUDGE:
) ACTION FILED:
15 Defendants. ) TRIAL DATE:
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REQUEST FOR INFORMAL DISCOVERY CONFERENCE
1 Be sure to modify these paragraphs to suit your individual
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situation. Do NOT just use the wording here unless it definitely applies
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to your particular situation.
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6 Be sure to remove this notice and all other notices before using
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this document.
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9 TO ________________, AND THEIR ATTORNEYS OF RECORD:

10 PLEASE TAKE NOTICE, that __________respectfully request(s), pursuant to the provisions


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of Code of Civil Procedure § 2016.080, that the court in the above-captioned action schedule an
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informal discovery conference for the purpose of discussing a discovery matter(s) in dispute between
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the parties.
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15 As further described in the declaration of _____________filed in support of this request, the

16 dispute concerns LIST HERE THE MATTER OR MATTERS IN DISPUTE SUCH AS A


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DEPOSITION, ETC. __________noticed the deposition for ________________________.
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The deposition notice specified ___ topics and included ________ demands for inspection of
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documents. ________________ objected and the parties have met and conferred, but have been
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21 unable to resolve their dispute as to ___ of the topics and ________ of the inspection demands.

22 ______________has indicated it plans to file a motion for protective order, which has the potential to
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considerably delay the deposition.
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The parties agreed to continue the deposition until __________ while they met and conferred
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in an attempt to resolve the discovery dispute.
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REQUEST FOR INFORMAL DISCOVERY CONFERENCE
1 __________________requests an informal discovery conference with the court to take place
2 before _______, to allow the parties to obtain the court’s guidance in order that the matter can be
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resolved without a formal motion and the deposition can go forward in a timely manner.
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6 Dated:_____________________ ____________________________________________
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ANY ATTORNEY OR PARTY

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REQUEST FOR INFORMAL DISCOVERY CONFERENCE
1 DECLARATION OF _____________________
2 I, _______________________, declare as follows:
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USE THE WORDING BELOW IF AN ATTORNEY IS SIGNING
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1. I am an attorney duly admitted to practice law before the courts of the State of
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California and the attorney of record for ___________ in the above-entitled action.

7 USE THE WORDING BELOW IF A PARTY IS SIGNING

8 1. I am ___________________________ in this action. I am over the age of 18 years and have


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personal knowledge of the facts contained in this declaration, and if called as a witness, could and
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would testify competently to the following.
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2. I have personal firsthand knowledge of the facts set forth herein and if called as a
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13 witness I could and would testify competently to the truth of the facts set forth in this declaration.

14 I make this declaration in support of the request that the court schedule an informal discovery
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conference for the purpose of discussing a discovery matter(s) in dispute between the parties.
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4. On __________, ____________was served by mail with LIST HERE SUCH AS A
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DEPOSITION NOTICE AND INSPECTION DEMANDS ETC. propounded by
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19 ________________.

20 5. _______________ objected to the deposition and the inspection demands on the grounds that
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LIST HERE THE GROUNDS FOR OBJECTION THAT ARE IN DISPUTE
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6. Before filing this Request, I made a reasonable and good faith effort to resolve informally
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each of the issues presented by this motion by LIST HERE YOUR EFFORTS SUCH AS
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25 SENDING A LETTER TO THE OTHER PARTY OR OPPOSING COUNSEL explaining the

26 relevance of each of the topics to be covered at the deposition and each of the disputed inspection
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REQUEST FOR INFORMAL DISCOVERY CONFERENCE
1 demands. A true and correct copy of said letter dated _________ is attached hereto as Exhibit “1”
2 and incorporated herein by reference.
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7. I then called ____________to discuss the disputed issues. While we were able to resolve
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certain issues, the following issues were not resolved: LIST HERE THE UNRESOLVED ISSUES.
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I declare under penalty of perjury under the laws of the State of California that the foregoing

7 is true and correct and that this declaration is executed on _________ at __________, California.

8 _______________________________________________________________
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NAME OF PERSON SIGNING DECLARATION

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REQUEST FOR INFORMAL DISCOVERY CONFERENCE
1 PROOF OF SERVICE
2 I am over the age of 18 and not a party to this action.
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I am a resident of or employed in the county where the mailing occurred; my business
4 address is: ADDRESS OF PERSON MAILING PAPERS.
5 On _______________,20___, I served the foregoing document(s) described as:
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REQUEST FOR INFORMAL DISCOVERY CONFERENCE to the following parties:

7 NAME AND ADDRESS OF ATTORNEY FOR OTHER PARTY OR OTHER PARTY

8 [X] (By U.S. Mail) I deposited such envelope in the mail at ______, California
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with postage thereon fully prepaid. I am readily familiar with the regular and
customary business practice of this office in which mail is duly deposited in
10 the United States Mail at __________, California on the date that it is mailed.
Under the practice it would be deposited with the U.S. Postal Service on that
11 same day with postage thereon fully prepaid at _____, California in the
ordinary course of business. I am aware that on motion of the party served,
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service is presumed invalid if postal cancellation date or postage meter date is
13 more than one day after date of deposit for mailing in affidavit.

14 [ ] (By Personal Service) I caused such envelope to be delivered by hand via


messenger service to the address above;
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16 [ ] (By Facsimile) I served a true and correct copy by facsimile during regular
business hours to the number(s) listed above. Said transmission was reported
17 complete and without error.
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I declare under penalty of perjury under the laws of the State of California that the foregoing
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DATED: ________________, 20___.
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22 _______________________________________
NAME OF PERSON MAILING PAPERS
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REQUEST FOR INFORMAL DISCOVERY CONFERENCE