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Meet and confer requirement prior to filing motion to
My style: I would call the guy, tell him your basis for the motion to quash
and request that he withdraw it. If he tells you to f off, follow up with a
very kind email asking him to withdraw the subpoena.
Whatever arguments you have for sanctions are amplified by his response.
What you tell him is: Hi Mark, how are you doing? Family good? How were the
holidays? I'm calling you about the subpoena, the deadline for discovery
has passed. I wanted to file a motion to quash but I thought I would ask
you first as a courtesy to you.
Sincerely,
*Michael Avanesian, Esq. *
Avanesian Law firm
101 N. Brand Blvd, PH 1920
Glendale, CA 91203
Office: 818.276.2477
Fax: 818.208.4550
On Wed, Jan 7, 2015 at 1:15 AM, Holly Roark hollyroark22@gmail.com [cdcbaa]
wrote:
>
>
> I reviewed the local bankruptcy rules but did not see a meet and confer
> requirement prior to filing a motion to quash a document subpoena and
> request for sanctions. Is anyone aware of a meet and confer requirement in
> this situation?
>
> Opposing side insists on conducting discovery after the cutoff date and I
> want to quash his subpoena and ask for sanctions. If we have to meet and
> confer, I'm not even sure what I'd tell him. He already served the subpoena
> on the witness and may already have the documents, which is bad enough even
> if he doesn't use them.
>
>
> Holly Roark
> Certified Bankruptcy Specialist*
> *and Sports Lawyer*
> holly@roarklawoffices.com **primary email address**
> www.roarklawoffices.com
> Central District of California
> Consumer Bankruptcy Attorney
> 1875 Century Park East, Suite 600
> Los Angeles, CA 90067
> T (310) 553-2600
> F (310) 553-2601
>
> *By State Bar of California Board of Legal Specialization
>
>
> **For a quicker response, email me at holly@roarklawoffices.com.
> I only use gmail for my listservs, and am likely to miss private emails
> directed to my gmail account.**
>
>
>
>
My style: I would call the guy, tell him your basis for the motion to quash and request that he withdraw it. If he tells you to f off, follow up with a very kind email asking him to withdraw the subpoena.Whatever arguments you have for sanctions are amplified by his response.What you tell him is: Hi Mark, how are you doing? Family good? How were the holidays? I'm calling you about the subpoena, the deadline for discovery has passed. I wanted to file a motion to quash but I thought I would ask you first as a courtesy to you.">Sincerely,Michael Avanesian, Esq.Avanesian Law firm101 N. Brand Blvd,PH 1920Glendale, CA 91203Office: 818.276.2477Fax: 818.208.4550
On Wed, Jan 7, 2015 at 1:15 AM, Holly Roark hollyroark22@gmail.com [cdcbaa] <
I reviewed the local bankruptcy rules but did not see a meet and confer requirement prior to filing a motion to quash a document subpoena and request for sanctions. Is anyone aware of a meet and confer requirement in this situation?Opposing side insists on conducting discovery after the cutoff date and I want to quash his subpoena and ask for sanctions. If we have to meet and confer, I&
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