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THE california discovery mANUAL

Tong Robbins LLP is excited to announce the arrival of the 2023 Edition of The California Discovery Manual, by Douglas Robbins. A portion of the Manual will soon be available on LexisNexis Practical Guidance. The Manual began life as the “Judge Pro Tem Discovery Manual” for the San Francisco Superior Court, articulating standard points of law regularly arising within discovery disputes. 

Stress-tested for over a half-decade by the Judge Pro Tems of the San Francisco Discovery Department, the Manual is now available for practitioners seeking clarity regarding the most-oft disputed issues arising in discovery motions. New to this edition, the Disco Manual offers Practice Notes from the perspective of the Master Strategist, the proverbial battle-hardened lawyer, with insight into the complex ways in which the rules interact, a judicial perspective on what makes for a compelling argument, and offering practical guidance on how to optimize outcomes.

PRACTICE NOTE: When Attorneys Instruct their Witnesses to Not Answer Deposition Questions

PRACTICE NOTE: Strategies in Responding to Discovery Demands

PRACTICE NOTE: Strategies in Pre-Motion Meet and Confer


With (and even without) party consent, the court may appoint what is known as a “discovery referee” to hear discovery motions and rule on evidentiary objections during depositions. See Cal.Civ. Proc. Code §§ 638-639. Especially complicated or contentious matters often do well to rely upon an experienced referee. Name-partner, Douglas Robbins provides that experience.


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