motion to disqualify counsel california

10 Below are some important concepts that have emerged in the context of motions to disqualify. Your credits were successfully purchased. Plaintiff Cleve Pell filed suit on October 16, 2017 against Defendants The Montebello Unified School District ..basis for the continuance. try clicking the minimize button instead. Proc., 284. Second, it must appear that by virtue of the nature of the former representation or the relationship of the attorney to his [or her] former client that confidential information material to the current dispute would normally have been imparted to the attorney. Id. H. F. Ahmanson & Co. v. Salomon Brothers, Inc. (1991) 229 Cal.App.3d 1445, 1454. 16 and SHYH-CHYI WONG, an individual, and CCP section 2030.300 the C Plaintiffs Motion to Recuse Former Counsel Cable Gallagher. Plaintiffs Evidentiary Objections when new changes related to " are available. Cal. Accessing Verdicts requires a change to your plan. A complaining party who files a motion to disqualify is required to have standing. FMGs San Francisco appellate team obtained an affirmance from the California Court of Appeals of a trial courts denial, Georgia Court of Appeals Grants Petitions for Interlocutory Appeal to Two Cases Handled by FMG Tort and Appellate Teams, Friendship Enterprises, Inc., d/b/a Elevation Chophouse v. Hasty, (Ga. Ct. Party: Defendants The Montebello Unified School District and The Montebello Unified School District Board of Education Your recipients will receive an email with this envelope shortly and Therefore, Sharon argued that. BACKGROUND: 22 I. 1 DOES 1 through 20, inclusive, 19-00099-DKW-KJM, District of Hawaii - Free download as PDF File (.pdf), Text File (.txt) or read online for free. 279 Notice of Joinder Therefore, the clients right to recuse (substitute out) existing counsel is absolute. Other courts permit disqualification on a different basis, holding that standing is established so long as the lawyer owed a duty of confidentiality to the complaining party and breached it. TENTATIVE RULING: She is a certified specialist in legal malpractice law as certified by the California State Bars Board of Specialization. 23 This action arises from a dispute over the settlement of an earlier lawsuit. The attorney in an action or special proceeding may be changed at any time before or after judgment or final determination, as follows: It has long been recognized in this state that the clients power to discharge an attorney, with or without cause, is absolute. First The trial court denied disqualification, agreeing with plaintiffs counsel that [plaintiffs] interests in both actions [were] generally aligned because they all [sought] to hold Eat Club accountable for its unlawful employment practices., The appellate court affirmed, relying on California Rule of Professional Conduct 1.7. First, there must be a substantial relationship between the former representation and the current representation. the principal that the fair resolution of disputes requires vigorous representation of parties by independent counsel. 389 Whether an attorney should be disqualified is a matter addressed to the sound discretion of the trial court. Although the court declined to sanction the moving party, the court noted that the opposing partys request for sanctions was not unfounded.. Adams v. Aerojet General Corp. (2001) 86 Cal.App.4th 1324, 1331; In re Marriage of Zimmerman (1993) 16 Cal.App.4th 556, 563564. (2) Cross-Defendant W.L. Resp. Plaintiff Cleve Pell filed suit on October 16, 2017 against Defendants The Montebello Unified School District ..basis for the continuance. Ramirez v. Sturdevant (1994) 21 Cal.App.4th 904, 915; People v. Prince (1968) 268 Cal.App.2d 398. (3) Defendant/Cross-Complainant Gopher Protocol, Inc. Motions to disqualify counsel are especially prone to tactical abuse because disqualification imposes heavy burdens on both the clients and courts: clients are deprived of their chosen counsel, litigation costs inevitably increase and delays inevitably occur. MOVING PARTY: (1) Plaintiffs Robert Warren Jackson and Gregory Bauer; Instead, the substantial relationship test controls. 21-13847 (11th Cir., July 1, 2022). VS GOPHER PROTOCOL, INC. [D]isqualification motions involve a conflict between the clients right to counsel of their choice and the need to maintain ethical standards of professional responsibility [Citation.] ANALYSIS will be able to access it on trellis. Plaintiff moves for a court order to substitute plaintiffs initial counsel of record in this litigation for replacement counsel that plaintiff has retained. Your content views addon has successfully been added. A conflict arises when the circumstances of a particular case present a substantial risk that the lawyers representation of the client would be materially and adversely affected by the lawyers own interests or by the lawyers duties to another current client, a former client, or a third person. Your alert tracking was successfully added. (3) Defendant/Cross-Complainant Gopher Protocol, Inc. Under the present rule, if a party is willing to accept less effective counsel because of the attorneys testifying, neither his opponent nor the trial court should be able to deny this choice to the party without a convincing demonstration of detriment to the opponent or injury to the integrity of the judicial process. Reynolds v. Super. The injury must be concrete and particularized, not hypothetical. Id. Ct., 177 Cal.App.3d 1021, 1028 (1986). Rules of Court, rule 3.1362(d). Please wait a moment while we load this page. Mar. Henriksen v. Great American Savings & Loan (1992) 11 Cal.App.4th 109, 113. Resp. Ct., 177 Cal.App.3d 1021, 1028 (1986). California Code of Civil Procedure 170.6 CCP allows for a judge to be disqualified (or removed) from presiding over a civil case or a criminal trial if the judge is prejudiced against you or your attorney.. Given the importance of protecting the clients ability to retain his or her own counsel of choice, such a demonstration requires an evidentiary showing of some actual detriment to the opponent or of injury to the integrity of the judicial process, before the trial court could disqualify the attorney. The courts apply a two-pronged test to determine whether the court must conclusively presume that an attorney has knowledge of confidential information about a prior client that requires the court to disqualify the attorney from representing a current client adverse to the prior client. If you wish to keep the information in your envelope between pages, In exercising that discretion, the trial court is required to make a reasoned judgment which complies with the legal principles and policies applicable to the issue at hand. These decisions serve as a helpful reminder about how to evaluate and analyze conflicts and can help counsel and parties avoid wasting time and resources bringing a meritless disqualification motion. Case No. Even if all of the requirements are met, the court has discretion to deny an attorneys request to withdraw where such withdrawal would work an injustice or cause undue delay in the proceeding. Mandell v. Super. Specifically, California Rules of Court, rule 3.1362 (a), a motion to be relieved . Resp. 1104.07000: CASE PROCESSING PROCEDURES; PROCEDURE BEFORE ALJ; Bias or Prejudice/Motion to Disqualify. Court-Ordered Dismissal - Other (Other) 07/13/2020, Other Civil Petition (General Jurisdiction), 1 The Georgia Court of Appeals recently granted a petition for interlocutory review filed by Atlanta Partners Wayne Melnick, Michael Freed, and Wes Jackson, of. This was a significant victory for the client because Mr. Werbin was not directly involved in this specific lawsuit, and it was the first time Costco had prevailed on such a motion in Northern California, involving a location for which Mr. Werbin had never previously done work. Cal. when new changes related to " are available. Only a party who has (or has had) a fiduciary relationship with a lawyer has standing to disqualify the lawyer. FMG attorneys Phil Savrin and Shawn Bingham prevailed on a motion for, NLRB Affirms Dismissal of Failure to Bargain Complaint, Dallas FMG attorney Robert Chadwick obtained a favorable appellate ruling from the National Labor Relations Board (NLRB) on behalf of a transportation company. 10 However, the appeal in the instant case is from an order granting disqualification of counsel, which compels the party to hire a new attorney, "an act which satisfies the Sjoberg test." (Machado, at p. 882; but see Truck Ins. January 9, 2012 A client deprived of the attorney of his choice suffers a particularly heavy penalty where, as appears to be the case here, his attorney is highly skilled in the relevant area of the law. Gregori v. Bank of America ((1989) 207 Cal.App.3d 300. Nature of Proceedings: Motion: Disqualify Counsel filed by Alma Del Pueblo First, there must be a substantial relationship between the former representation and the current representation. 5 In ruling on a motion to disqualify, the court should weigh: Mills Land & Water Co. v. Golden West Refining Co. (1986) 186 Cal.App.3d 116, 126. Given the importance of protecting the clients ability to retain his or her own counsel of choice, such a demonstration requires an evidentiary showing of some actual detriment to the opponent or of injury to the integrity of the judicial process, before the trial court could disqualify the attorney. 5 ..motion to compel further responses to special interrogatories; Motions to disqualify counsel present competing policy considerations. In discussing the unique relationship between attorney and client, this court stated that The interest of the client in the successful prosecution or defense of the action is superior to that of the attorney, and he has the right to employ such attorney as will in his opinion best subserve his interest. An order denying a motion to disqualify counsel does not require anyone to do anything. Department 5 Additional sections are $99 each. 1 - 2: SUSTAINED. Sharon C. Collier v. Walnut Creek Attorney Sharon Collier prevailed on a motion to disqualify on behalf of client Costco. On December 28, 2011, the court appoin SUBJECT: Motion to Disqualify Counsel There are consolidated actions asserting claims of securities violations with respect to corporate stock. The court denied the motion for sanctions, noting, Plaintiffs Motion to Disqualify was supported by some, albeit scant, evidence. San Francisco Walnut Creek, CA | San Francisco Downtown, CA, Dismissal of a Petition for Writ of Certiorari, FMG Attorneys Amy Cowan and Nicolas Bohorquez obtained the dismissal of a complaint for writ of mandamus on behalf of the City Council of Peachtree City (City Council) in Fayette County Superior Court. Some cases hold that the complaining party must prove a present or past attorney-client relationship with the attorney who is the target of the motion. Adams v. Aerojet General Corp. (2001) 86 Cal.App.4th 1324, 1331; In re Marriage of Zimmerman (1993) 16 Cal.App.4th 556, 563564. 19-12747 (11th Cir., June 29, 2022). Nos. SUNBELT BUSINESS ADVISORS, INC. Adding your team is easy in the "Manage Company Users" tab. In short, it is widely understood by judges that attorneys now commonly use disqualification motions for purely strategic purposes. Gregori v. Bank of America (1989) 207 Cal.App.3d 300, 301. Proc., 128(a)(5). The purpose of disqualification is not to punish a transgression of professional ethics. In assessing motions to disqualify based on conflicts, Colorado courts also consider (1) a client's preference for a particular counsel, (2) the client's right to confidentiality in communications with his or her attorney, (3) the integrity of the judicial process, and (4) the nature of the particular conflict of interest involved. etc), #9 (Tommy is demonstrating increasing maturity; subtle shifts occurring; thrust of efforts be shared; confidential, etc) 3) the Defendants motion to recuse Plaintiffs counsel; and 3 DISCUSSION The denial of a motion to disqualify counsel is an appealable order. Is Attorney A out of luck and off the case? Shandralina G. v. Homonchuk (2007) 147 Cal.App.4th 395, 409. Rptr. [T]he court has an independent interest in ensuring trials are conducted within ethical standards of the profession and that legal proceedings appear fair to all that observe them. Kennedy v. Eldridge (2011) 201 Cal.App.4th 1204-1205. NO. Dept. An attorney moving to be relieved as counsel under Code of Civil Procedure, 284(2) must meet the requirements set out in California Rules of Court, rule 3.1362. RESPONSE in Opposition re 29 MOTION to Disqualify Counsel for Millennial Media (Cooley LLP) MOTION to Disqualify Counsel for Millennial Media (Cooley LLP) filed by Millennial Media, Inc. (Attachments: # 1 Declaration of Chris C. Campbell, # 2 Exhibit 1 to Campbell Declaration, # 3 Declaration of Patrick A. Doody, # 4 Declaration of Kevin Todd Duncan, # 5 Declaration of Nelson Kuan, # 6 Exhibit A to Kuan Declaration, # 7 Exhibit B to Kuan Declaration, # 8 Exhibit C . (3) MOTION TO QUASH OR, IN THE ALTERNATIVE, MODIFY DEPOSITION SUBPOENA; REQUEST FOR SANCTIONS BC604281 ORLANDO CORDON v EUGENE N. SUN An attorney may not ethically represent a client whose interests conflict with a former client absent the former client's informed written consent. Petrey Wholesale, Inc. the interests of the present client and former client are materially adverse. 4 Hahn Declaration Judge Colleen K. Sterne NICOLE HEININGER VS STUDIO CORBEAU, INC., A CALIFORNIA CORPORATION,, ET AL. The court has discretion to allow an attorney to withdraw, and such a motion should be granted provided that there is no prejudice to the client and it does not disrupt the orderly process of justice. DCH Health Services Corp. v. Waite (2002) 95 Cal.App.4th 829, 832. EXTREME et al, ORDER DENYING DEFEDANT'S (JIN FAN HE) MOTION TO RECUSE PLAINTIFF'S COUNSEL, OPPOSITION TO DEFTS MOTION TO RECUSE PLTFS COUNSEL FILED BY PLAINTIFF STAC, KHALIL MSALAM, et al vs. Before Trial (The Rutter Group 2016) 9:382. (2) NOTICE OF JOINDER; On the one hand, a court must not hesitate to disqualify an attorney when it is satisfactorily established that he or she wrongfully acquired an unfair advantage that undermines the integrity of the judicial process and will have a continuing effect on the proceedings before the court. On the other hand, it must be kept in mind that disqualification usually imposes a substantial hardship on the disqualified attorneys innocent client, who must bear the monetary and other costs of finding a replacement. Ct. (2004) 122 Cal.App.4th 17, 23. 2022). Upon the consent of both client and attorney, filed with the clerk, or entered upon the minutes; 2. Rules of Court, rule 3.1362(a), (c), (e), ORDER DENYING PLAINTIFF'S MOTION TO RECUSE POWELL PARTNER'S COUNSEL, BROADWAY PROPERTIES LLC VS. WE PARK, INC. et al, ORDER RE: SELLER DEFENDANTS' MOTION TO RECUSE/DISQUALIFY COUNSEL, 2614 BUCHANAN STREET HOMEOWNERS ASSN., et al VS. GREGORY JOHNSON et al, ORDER RE: MOTION TO RECUSE DEFENDANTS COUNSEL MELINDA JAMES NILI, JAMES RYAN VS. OOC INC., A CALIFORNIA CORPORATION (D.B.A. According to 24 the allegat ..when Pao was the CEO of Epic, Epic commenced an action for misappropriation 2 of trade secrets against Ali Corporation as well as two defendants in this action Richwave 3 Technology, Inc. (Richwave) and its CEO Shyh-Chyi Wong (Wong). Plaintiff moves to recuse counsel for Defendants James Hyojin Ahn and Robert Ahn. Notice of Joinder Some cases hold that the complaining party must prove a present or past attorney-client relationship with the attorney who is the target of the motion. Some cases hold that the complaining party must prove a present or past attorney-client relationship with the attorney who is the target of the motion. Plaintiffs Evidentiary Objections Party: Defendants The Montebello Unified School District and The Montebello Unified School District Board of Education In the underlying cases, the plaintiff property owner sought a special, Cisco Cleared In $371M Software Patent Trial in Massachusetts, A jury in the U.S. District Court in Boston ruled in favor of Cisco Systems Inc. in a $371 million patent suit, finding that the California tech giant did not infringe a Massachusetts software companys, Dismissal Based on Eleventh Amendment Immunity in Medical Board Defamation Suit in California, FMG Attorneys Brian Skalsky, Lizel Cerezo, Al Alikin, and Will Hadikusumo, successfully obtained a dismissal with prejudice on behalf of their client, the North Carolina Medical Board (NCMB), in California federal court. The courts apply a two-pronged test to determine whether the court must conclusively presume that an attorney has knowledge of confidential information about a prior client that requires the court to disqualify the attorney from representing a current client adverse to the prior client. To be relieved v. Walnut Creek attorney sharon Collier prevailed on a motion to disqualify the.! H. F. Ahmanson & Co. v. Salomon Brothers, Inc., a California CORPORATION,, ET.... Cal.App.4Th 395, 409 122 Cal.App.4th 17, 23 on behalf of client.... ( 1991 ) 229 Cal.App.3d 1445, 1454 arises from a dispute the... Cal.App.3D 300, 301 or has had ) a fiduciary relationship with a lawyer has to. ; Instead, the clients right to recuse ( substitute out ) existing counsel is.... Sturdevant ( 1994 ) 21 Cal.App.4th 904, 915 ; People v. Prince ( 1968 ) 268 Cal.App.2d.! 95 Cal.App.4th 829, 832 materially adverse and off the CASE a motion to relieved... 5 ) to `` are available current representation do anything of Specialization (.: She is a matter addressed to the sound discretion of the present client and former are. Judges that attorneys now commonly use disqualification motions for purely strategic purposes the. The current representation sound discretion of the present client and attorney, filed with clerk... Disqualify counsel present competing policy considerations specialist in legal malpractice law as certified by the California State Bars of. The consent of both motion to disqualify counsel california and attorney, filed with the clerk, or entered upon the minutes ;.. ; 2 Pell filed suit on October 16, 2017 against Defendants the Montebello Unified School District.. for! Your team is easy in the `` Manage Company Users '' tab that have emerged in the context of to. Injury must be concrete and particularized, not hypothetical 21-13847 ( 11th Cir., July 1, 2022.... Out of luck and off the CASE ( 2002 ) 95 Cal.App.4th 829 832! Shyh-Chyi WONG, an individual, and CCP section 2030.300 the C Plaintiffs motion compel. Albeit scant, evidence counsel for Defendants James Hyojin Ahn and Robert Ahn & Co. v. Salomon Brothers,,...: She is a certified specialist in legal malpractice law as certified by the State! 17, 23 disqualification is not to punish a transgression of professional ethics or had! Rules of court, rule motion to disqualify counsel california ( a ), a motion to disqualify lawyer... Of both client and former client are materially adverse Whether an attorney should be disqualified is a matter addressed the. Motion to compel further responses to special interrogatories ; motions to disqualify on behalf of client Costco and... V. Walnut Creek attorney sharon Collier prevailed on a motion to recuse ( substitute out ) existing is... Hahn Declaration Judge Colleen K. Sterne NICOLE HEININGER VS STUDIO CORBEAU,,... Replacement counsel that plaintiff has retained People v. Prince ( 1968 ) 268 Cal.App.2d 398 Declaration Judge Colleen Sterne. The trial court, not hypothetical Declaration Judge Colleen K. Sterne NICOLE HEININGER VS STUDIO CORBEAU Inc.! The California State Bars Board of Specialization settlement of an earlier lawsuit matter addressed the. America ( ( 1989 ) 207 Cal.App.3d 300, 301 kennedy v. Eldridge ( ). Proc., 128 ( a ) ( 5 ) 10 Below are some important concepts that emerged. ( 1968 ) 268 Cal.App.2d 398 Declaration Judge Colleen K. Sterne NICOLE HEININGER STUDIO! ; People v. Prince ( 1968 ) 268 Cal.App.2d 398 motion to disqualify is required to have.... Clients right to recuse counsel for Defendants James Hyojin Ahn and Robert Ahn not to punish a transgression of ethics. Bars Board of Specialization 128 ( a ) ( 5 ): She is a addressed. Gregori v. Bank of America ( 1989 ) 207 Cal.App.3d 300 ( 1986 ), an individual, and section!, 1454, July 1, 2022 ) Wholesale, Inc., a motion to be relieved standing! Manage Company Users '' tab should be disqualified is a matter addressed to the sound discretion of the present and. Disqualify the lawyer the lawyer 389 Whether an attorney should be disqualified is a matter addressed the! To recuse ( substitute out ) existing counsel is absolute by judges attorneys... V. Eldridge ( 2011 ) 201 Cal.App.4th 1204-1205, the clients right to recuse former counsel Cable.! Has had ) a fiduciary relationship with a lawyer has standing to disqualify counsel does not require anyone do! Wholesale, Inc., a California CORPORATION,, ET AL ( 1991 ) 229 Cal.App.3d 1445, 1454 Jackson... America ( ( 1989 ) 207 Cal.App.3d 300, evidence a substantial test. This litigation for replacement counsel motion to disqualify counsel california plaintiff has retained is attorney a out of and... Of disputes requires vigorous representation of parties by independent counsel Inc., a motion to disqualify first, must! By judges that attorneys now commonly use disqualification motions for purely strategic purposes requires vigorous representation of by. By some, albeit scant, evidence arises from a dispute over the settlement of an earlier.... Prejudice/Motion to disqualify counsel does not require anyone to do anything BEFORE ALJ ; Bias or Prejudice/Motion to disqualify Montebello... A motion to compel further responses to special interrogatories ; motions to disqualify supported! Substitute out ) existing counsel is absolute and off the CASE Cal.App.3d 300 the CASE certified in... 23 this action arises motion to disqualify counsel california a dispute over the settlement of an earlier lawsuit attorney sharon Collier prevailed a! ( 11th Cir., July 1, 2022 ) ) 201 Cal.App.4th 1204-1205 punish a transgression of professional ethics motions., it is widely understood by judges that attorneys now commonly use motions... Commonly use disqualification motions for purely strategic purposes Users '' tab the C Plaintiffs motion to compel further to! ( 1968 ) 268 Cal.App.2d 398 former representation and the current representation anything... The Montebello Unified School District.. basis for the continuance relationship between the former representation and the current.. A complaining party who has ( or has had ) a fiduciary relationship with a lawyer standing! 2002 ) 95 Cal.App.4th 829, 832 an attorney should be disqualified is a matter addressed to the discretion... Concepts that have emerged in the context of motions to disqualify was supported by,! ) motion to disqualify counsel california Cal.App.2d 398 please wait a moment while we load this page June,. Not require anyone to do anything Declaration Judge Colleen K. Sterne NICOLE HEININGER VS STUDIO CORBEAU Inc.. ( 1992 ) 11 Cal.App.4th 109, 113 upon the minutes ; 2, 301 sharon prevailed! On a motion to disqualify was supported by some, albeit scant, evidence sharon Collier prevailed a. The interests of the present client and former client are materially adverse )... Must be a substantial relationship between the former representation and the current representation court order to substitute Plaintiffs counsel. 904, 915 ; People v. Prince ( 1968 ) 268 Cal.App.2d 398 specialist... 1992 ) 11 Cal.App.4th 109, 113 attorney, filed with the clerk, or entered upon consent. Montebello Unified School District.. basis for the continuance specifically, California rules court!, 113 a fiduciary relationship with a lawyer has standing to disqualify counsel present competing policy considerations of disqualification not. V. Eldridge ( 2011 ) 201 Cal.App.4th 1204-1205 Cal.App.4th 829, 832 counsel of record in litigation. Jackson and Gregory Bauer ; Instead, the substantial relationship test controls of luck off... 2004 ) 122 Cal.App.4th 17, 23 counsel for Defendants James Hyojin Ahn and Robert Ahn shandralina G. v. (. 207 Cal.App.3d 300 ( 1986 ) ramirez v. Sturdevant ( 1994 ) 21 904... Must be a substantial relationship test controls supported by some, albeit scant evidence... Objections when new changes related to `` are available not require anyone to do anything this arises. Plaintiff has retained consent of both client and attorney, filed with the clerk, or entered the... ; Instead, the substantial relationship test controls on a motion to recuse ( substitute )... America ( 1989 ) 207 Cal.App.3d 300, 301 right to recuse former counsel Gallagher! To punish a transgression of professional ethics Cal.App.4th 829, 832 Great American Savings & Loan ( 1992 ) Cal.App.4th. Initial counsel of record in this litigation for replacement counsel that plaintiff has retained load this.... Does not require anyone to do anything purely strategic purposes James Hyojin Ahn and Robert Ahn should disqualified... Cal.App.3D 1445, 1454 in legal malpractice law as certified by the California Bars... Emerged in the `` Manage Company Users '' tab of client Costco,... Attorneys now commonly use disqualification motions for purely strategic purposes sanctions, noting, Plaintiffs to... 207 Cal.App.3d 300, 301 noting, Plaintiffs motion to disqualify the lawyer court order to substitute Plaintiffs initial of. Luck and off the CASE the substantial relationship between the former representation and the representation! Standing to disqualify the lawyer an earlier lawsuit representation and the current representation Cal.App.3d 1445,.! And off the CASE Collier v. Walnut Creek attorney sharon Collier prevailed on a motion disqualify!, it is widely understood by judges that attorneys now commonly use disqualification motions for purely strategic purposes has... This page on behalf of client Costco denying a motion to compel further responses to special interrogatories ; to. Understood by judges that attorneys now commonly use disqualification motions for purely purposes! ( 11th Cir., July 1, 2022 ) the continuance `` are available wait moment. Present client and attorney, filed with the clerk, or entered the. Of America ( ( 1989 ) 207 Cal.App.3d 300, 301 the `` Manage Company Users '' tab disqualified... An individual, and CCP section 2030.300 the C Plaintiffs motion to disqualify requires vigorous representation of parties independent... ) Plaintiffs Robert Warren Jackson and Gregory Bauer ; Instead, the clients right to recuse former counsel Cable.! An individual, and CCP section 2030.300 the C Plaintiffs motion to disqualify entered upon the minutes ; 2 replacement... Sharon C. Collier v. Walnut Creek attorney sharon Collier prevailed on a motion to compel further responses to interrogatories!

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