Employee Rest Periods

Sometimes you have to compel the opposition's response to discovery. But before you can move to compel, you are required to "meet and confer." If you do the "meet and confer" wrong, your discovery motion will be doomed.

A common area of abuse occurs when attorneys instruct their clients to not answer a deposition question. Instructions to refuse to answer should occur only in response to questions implicating a privilege. All other instructions to not answer questions for relevance, for hearsay, or even for “harassment,” are improper.

The firm is pleased to report that in a hard fought matter spanning eight years, after a trial, and after four years on appeal, the California Court of Appeal ruled in favor of Tong Robbins’ clients, holding, in plain language, “We agree with plaintiffs.”