Downward arrow
Civic Center Dome,
San Francisco, California
THE california discovery mANUAL

Tong Robbins LLP is excited to announce the arrival of the updated 2024 Edition of The California Discovery Manual, by Douglas Robbins. 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 articulates standard points of law, and offers strategies in making and defending discovery motions filed in the California Superior Courts. 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.


Initial consultations are always free of charge.
Whether we engage as your lawyers or not, we always keep your
communications privileged and confidential.