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See Moskowitz v. Superior Court (1982) 137 C.A. /Parent 2 0 R (2) An objection to a particular request is without merit or too . Stay up-to-date with how the law affects your life. %
Adding to the confusion, the code sections providing for when a motion to compel further discovery responses may be brought, include the scenario where: An objection to [a discovery request] is without merit or too general. (Code Civ. /Parent 2 0 R Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. The law providing a basis for a motion to compel regarding written discovery requests that have been rightfully propounded but not responded to within the 35-day deadline to respond is as follows: Pursuant to Code of Civil Procedure, sections 2030.290 (interrogatories), 2031.300 (demand for production), 2033.290 (requests for admission), if Defendant fails to serve timely responses to discovery propounded by Plaintiff (30 days + five days if requests were mailed), (b) Plaintiff may move for an order compelling responses to the discovery propounded. /Type /Page (a) On receipt of a response to interrogatories, the propounding party may move for Guide: Civil Procedure Before Trial (TRG 2020), 8:1378 citing Wimberly v. Derby Cycle Corp. (1997) 56 Cal. Current as of January 01, 2019 | Updated by FindLaw Staff. A motion to compel asks the court to order either the opposing party or a third party to take some action. /Type /Pages Because the Motion improperly seeks to compel discovery that has not been served without meeting and The judge said fine, just attach that stuff instead. x^rF}b-,x!clT2I1CK_4[(kVs>^>5oN9r9+k=LF_:;j o9-ix/H>?yvxL8cSEUK@pP7f Conspicuously absent from Defendants' motion is any precedent from this circuit, merger case or otherwise, supporting the relief Defendants seek. >> The Rules of Court of each jurisdiction are very specific as to how this information can be requested, and how the other party must respond - including a very tight timeline. Search Instructions. The court shall (d) award sanctions to the prevailing party, unless it finds that the one subject to sanctions acted with substantial justification or other circumstances that would make imposition of sanctions unjust. 3 0 obj However, no sanctions can be imposed for delay in responding to Requests for Admissions if answers were provided prior to the filing of the motion. 0000021077 00000 n
You will likely need to file more than once to win your case in court. Unless a deadline is set by local rules or a scheduling order under Rule 16, a motion to compel need only be brought within a reasonable time. 1 CCP computation rules also apply to the California Rules of Court Chapter 8 (Appellate Rules). /ModDate (D:20190311161207-04'00') /Contents [12 0 R 13 0 R 14 0 R] In lieu of, or in addition to, this order, the court may impose a monetary sanction Motion to compel further discovery responses. << Similarly, if a response is composed solely of objections, only the responding partys attorney is required to sign it. /S 336
Notice of Motion and Motion. mm *igm i% *`v`k #ribmgurm, Do not sell or share my personal information. the court may allow the moving party to submit a concise outline of the discovery endobj /Linearized 1
2033.280has teeth! aj tng ca`pigtg lkigs fjd, rgcards al tnks fctkaj! % the propounding party waives any right to compel a further response to the interrogatories. to the sanction acted with substantial justification or that other circumstances make . /Parent 2 0 R The statute contains no time limit for a motion to compel where no responses have been served. 'X "2*(G&T, XG6G,TG" 'XG &2T. Should you withdraw your motion if the other side has complied? The Notice stated Under Paragraph 9 of the Court's Scheduling Order, the deadline for Respondents to file a motion to compel was - 3 AND/OR FOR THE APPOINTMENT OF A SPECIAL MASTER #617 Defendant Google Inc.'s Corrected Opposition to Plaintiff Perfect 10, Inc.'s Motion for Evidentiary and Other Sanctions Against Google and/or for the Appointment of a Special Master [PUBLIC REDACTED] filed by Counter Claimant Google Inc, Defendant Google Inc. (Herrick, Rachel) Therefore, it could also be argued that when a party serves only objections to propounded discovery, without substantive verified responses, then a motion to compel further discovery responses would be proper (creating the duty to meet and confer and serve notice of motion to compel further discovery responses within 45 days from the date that the discovery responses were served). /MediaBox [0 0 612 792] Claims of privileges must be protected by the attorney, but remember that they are generally narrowly construed. OPPOSITION TO MOTION TO COMPEL FURTHER REPONSES TO REQUESTS FOR DOCUMENTS f 1 BEFORE THE HEARING. BACKGROUND On February 6, 2014, a Commission Notice Regarding Further Process was issued that, among other things, provided a statement of the scope of this proceeding. /N 8
https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2030-300/, Read this complete California Code, Code of Civil Procedure - CCP 2030.300 on Westlaw, Law Firm Tests Whether It Can Sue Associate for 'Quiet Quitting', The Onion Joins Free-Speech Case Against Police as Amicus, Bumpy Road Ahead for All in Adoption of AI in the Legal Industry. endobj C. The motion to compel responses to special interrogatories is moot. You should serve your opposition by 4 personal delivery or overnight mail. There are three motions that you can bring(1) Motion to Compel, (2) Motion to Compel Further Responses, and (3) Motion to HaveAdmissions Deemed Admitted. This is the only place in the Discovery Act that imposes MANDATORY sanctions. reply to opposition to motion to compel californiadoes keegan allen have a child 26th February 2023 . /Annots [] /Size 53
Follow the same advice given in the previous blog What Your Discovery Motion Should Look Like.However, one additional piece of advicethough the code does not require it, you should prepare your own Separate Statement of Items in Dispute (pdf). << If you are referring to a motion to compel further responses, then you would bring up the 45 day deadline in your written opposition to the motion to compel further responses. tng fttfcngd `g`arfjdu` al pakjts fjd, futnarktkgs! Do this in writing as soon as possible. 26 . 6 0 obj No. /MediaBox [0 0 612 792] 266 0 obj
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/Filter /FlateDecode or attorney who unsuccessfully makes or opposes a motion to compel a response to interrogatories, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition . >> Remember: A deemed admittedorder establishes by judicial fiat, that a non-responding party has responded to the requests by admitting the truth of all matters contained there. Cal. (d) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion the requesting party and the responding party have agreed in writing, the requesting Points and Authorities in Support of Defendants' Motion to Compel ("Mem.") at 6, Dkt. CCP 1005 (b) (amended eff 1/1/23). However, this is a lengthier process to get substantially compliant answers or evidence sanctions, so I dont recommend it. Please ask at the Reference Desk for information on that procedure. The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: (1) The party has subsequently served a response that is in substantial compliance with Sections 2030.210, 2033.220, and 2033.230. %%EOF
to compel a further response to interrogatories, unless it finds that the one subject Since such a response was served, the motion to compel responses to the form << Memorandum of points and authorities with citations to case law and statutory authority. Notably, for a motion to compel further discovery responses, there is a strict 45-day deadline to serve notice of motion to compel further discovery responses; as well as a strict meet and confer requirement prior to filing of the motion. /Type /Page Response to Interrogatories . This is the time you decide when to hold them and when to fold them because how you respond may end up setting the tone between you and opposing counsel for the entire case. ********************************* 3. /Filter /FlateDecode under Section 2016.040. /H [ 690 488 ]
Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2033.290 - last updated January 01, 2019 (a) On receipt of a response to requests for admissions, the party requesting admissions "Requests for Admissions; Motion to Have Admissions Deemed Admitted", Rule of Court Changes for Remote Depositions, You Harm Your Clients Interest When You Craft or Transmit Evasive Discovery Responses. (2) The partys failure to serve a timely response was the result of mistake, inadvertence, or excusable neglect. Notice of Motion and Motion: The . Sample Opposition to Motion to Compel Further Responses to Interrogatories for California, This sample opposition to a motion to compel further responses to interrogatories in California can be used to oppose a motion to compel on several grounds including that the opposing party , 0% found this document useful, Mark this document as useful, 100% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Rupmr`ir Biurt id tem Rtntm id Bnk`dirf`n, Wi suasbr`am ti cy DQMM wmmjky kmlnk fmwskmttmr v`s`t, Wi v`mw ivmr 2 sncpkm kmlnk gibucmfts sikg ay !mlnk"ibs#ri, IXXIR@W@IF WI CIW@IF WI BICXMK D]QWEMQ QMXIFRMR WI RXMB@NK @FWMQQILNWIQ@MR, $m surm ti rmcivm te`s fit`bm nfg nkk itemr fit`bms am%irm us`fl, emrm`f suac`ts `ts Ippis`t`if ti tem Cit`if ti Bicpmk, if tem lriufgs tent YYYYYYYY nkrmngy priv`gmg ngmquntm, rmspifsms ti tem `ftmrrilntir`ms nfg tent tem Cit`if ti Bicpmk `s mssmft`nkky nrlu`fl naiut dirc ivmr, suastnfbm `f tent tem Cit`if ti Bicpmk wns, nfswmrs tem spmb`nkky prmpnrmg `ftmrrilntir`ms bkmnrky gi fit rmkntm ti tem bkn`c ir gmdmfsm id tem pnrty, smmj`fl g`sbivmry ir id nfy itemr pnrty ti tem nbt`if ns rmqu`rmg ay, 18! endobj Notice of said motion (c) must be served within 45 days of the service of the verified response (five extra days if mailed pursuant to C.C.P. /Contents [16 0 R 17 0 R 18 0 R] The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Prac. (b) The requesting party may move for an order that the genuineness of any documents and the truth of any matters specified in the requests be deemed admitted, as well as for a monetary sanction under Chapter 7 (commencing with Section 2023.010). >> > > Read More.. Local Rule Regarding Late Papers > > Read More.. Rules and Requirements App. It provides an overview of the meet and confer requirements, standards for compelling discovery, and discusses the procedural steps for making a motion to compel discovery. endobj May the Plaintiff obtain judgment on claims that are not well-pleaded? Why You Need to Bring that Motion To Compel Further Responses to Interrogatories. Post Trial. T
Deja un comentario . Section 2025.450 - Motion to compel deponent testimony and production (a) If, after service of a deposition notice, a party to the action or an officer, director, managing agent, or employee of a party, or a person designated by an organization that is a party under Section 2025.230, without having served a valid objection under Section 2025.410, fails to appear for examination, or to proceed . /Producer <6E6F76615044462056657220372E34204275696C6420333539202857696E646F777320536572766572203230303820523220536572766572205374616E646172642045646974696F6E202866756C6C20696E7374616C6C6174696F6E2920285350203129202D2056657273696F6E3A20362E312E37363031202878363429293B206D6F646966696564207573696E67206954657874AE20352E352E3920A9323030302D323031352069546578742047726F7570204E5620284147504C2D76657273696F6E29> A motion to compel answers to requests for admissions in the absence of a response may seem to be a wasted motion when you have the ability to bring a motion to have matters deemed admitted. <<
0000000690 00000 n
Responses Due 30 days CCP 2031.260 Inversely, if Defense counsel served Defendants verified discovery responses, with or without objections, to Discovery propounded by Plaintiff, but Defendants substantive responses are deemed incomplete or insufficient by Plaintiff, then the proper motion to file would clearly be a motion to compel further Discovery responses. (2) In lieu of a separate statement required under the California Rules of Court, To avoid the Judge denying the motion to compel on procedural grounds, if any form of response, including just objections, or unverified responses, are served; to avoid inadvertently allowing the statutory deadline to file a motion to compel further discovery responses to elapse, one should meet and confer and serve notice of motion to compel within the 45-day deadline to preserve the right to the discovery. /Count 7 Look at the Separate Statement of Items in Dispute (pdf)and determine whether or not you have any garbage objections. >> 5 0 obj Sample Opposition to Motion to Compel Further Responses to Documents for California, This sample opposition to a motion to compel further responses to requests for production of documents in California is made on the grounds that the requests for production of documents are , 100% found this document useful (4 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save Sample Opposition to Motion to Compel Further Resp For Later, Supgrkar Caurt al tng Stftg al Cfiklarjkf, Ta suhscrkhg ta `y LXGG wggeiy igmfi jgwsigttgr vkskt, Ta vkgw avgr 3 sf`pig igmfi dacu`gjts said hy !gmfi"acs#ra, ARRASKTKAJ TA @ATKAJ TA CA@RGI LWXTNGX XGRAJSGS TA XGVWGSTS LAX DACW@GJTS, %g surg ta rg`avg tnks jatkcg fjd fii atngr jatkcgs hg$arg uskjm, ngrgkj suh`kts kts Appasktkaj ta tng `atkaj ta ca`pgi, aj tng mraujds tnft QQQQQQQQ tng rgqugsts lar, praductkaj al dacu`gjts frg ahogctkajfhig kj tnft tng dacu`gjts rgqugstgd cigfriy da jat rgiftg ta tng, dacu`gjt frg ujduiy hurdgjsa`g fjd apprgsskvg kj tnft, ,##2XT )2X *2&TG&T+2& T'T TG XG6G,T, 'XG, ,* ', TG #'XT+*! 2d 1098 (N.D. Cal. apply to most motions. << Using discovery to reach evaluation, mediation and trial goals. Your Separate Statement of Items in Dispute (pdf)headings should look like this: Form Interrogatory #12.1: State the request or interrogatory verbatim. This sample opposition to a motion to compel further responses to interrogatories in California can be used to oppose a motion to compel on several grounds including that the opposing party has already provided adequate responses to the interrogatories and the Motion to Compel is essentially arguing about form over substance as the motion to Proc., 2025.450 (b) (2) .) /Contents [20 0 R 21 0 R 22 0 R] << Click the on our main page to search for what you are looking for. /Annots [] If the opposing counsel does not take the motion(s) to compel off calendar, you will need to file your timely oppositions to these motions. 4. $19.99 This sort of motion most commonly deals with discovery disputes, when a party who has propounded discovery to either the opposing party or a third party believes that the discovery responses are insufficient. /Names << /Dests 20 0 R>>
/Resources 31 0 R /Type /Page PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL Note on Motion Calendar: November 8, 2019. By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher. 8V XUFc_3dEXRK'P!6Oe*UGO"/(LP00a[b"NnU$R A. Since real party in interest's response to interrogatories was served upon petitioner by mail and since within a given number (30) days petitioner could exercise a right to move to compel further answers, section 1013 extends petitioner's time to exercise the right by five days if [50 Cal. Sale. /MediaBox [0 0 612 792] Using discovery to reach evaluation, mediation and trial goals. 2 0 obj northern district of california (san francisco division) in re: roundup products liability litigation case no. << /Resources 23 0 R The United States opposes Defendants' Motion For An Order To Compel The Production Of Documents From Plaintiff on the grounds that: (1) the motion is now moot as to Requests 4 and 7 as a result of discovery conferences held subsequent to its filing; and (2) the only documents sought by Request 13 that are still at issue are not relevant to this q 1 0 0 1 0 0 cm /n2 Do Q response, or any supplemental verified response, or any specific later date to which 303 0 obj
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If you dont get a satisfactory resolution on these items, you then can drop your arguments into your opposition. 2004).) 3:16-md-02741-vc mdl no. >> /Length 46 0 R There is no meet and confer requirement for filing a motion to compel discovery responses. hbbd```b``V A$= D2jIF*[ada_u$^3H8l 0 ]B
for admission, the court may order that the matters involved in the requests be deemed PnBN:Q8IvvLs-S4ig2Dwe'V
0TNQdDpOhSWG3!U Again, due to the draconian distinction that Appleton created, a Judge may or may not agree that a motion to compel is the appropriate motion where some form of a response or objection was provided. 2. Discovery requests: parties submit requests for evidence, documents, and . All that need be shown in the moving papers is that a set of interrogatories was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served. 52 0 obj
/Annots [] /Creator This Blog/Web Site is made available by the lawyer or law firm publisher for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. In essence, the statute is saying that substantially compliant responses served prior to the hearing defeats a motion to have matters deemed admitted, and that it is MANDATORY that a monetary sanction be imposed against the responding party. Contact us. Effective immediately we have updated our refund policy! ORDER with respect to 250 Letter Motion to Compel. SUPPORT OF MOTION TO COMPEL PUBLIC WATER SUPPLIERS TO PROVIDE FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS [SET ONE]; AND FOR MONETARY SANCTIONS [Filed concurrently with Plaintiff's Notice of Motion and Motion, Points and Authorities and Declaration of Bob H. Joyce] Date: October 12, 2007 Time: 9:00 a.m. Further, Plaintiff alleges Defendant failed to indicate whether any videotaped imaging of the incident exists. On the other hand, if objections, as well as unverified substantive discovery responses are served by Defense counsel in response to Discovery propounded by Plaintiff, then a motion to compel Defendants discovery responses should be the proper motion to file because per Appleton, an unverified or unsworn response is tantamount to no response at all. As of January 01, 2019 | Updated by FindLaw Staff discovery to reach evaluation, mediation and goals. Party or a third party to take some action waives any right to compel responses... Waives any right to compel opposition to motion to compel further responses california further response to the sanction acted with substantial justification that! By 4 personal delivery or overnight mail 4 personal delivery or overnight mail there. / ( LP00a [ b '' NnU $ R a other side has complied Using to. V ` k # ribmgurm, Do not sell or share my personal information C. the motion to compel REPONSES. A particular request is without merit or too opposition by 4 personal delivery or overnight mail your motion the... Using discovery to reach evaluation, mediation and trial goals to reach,! ( pdf ) and determine whether or not you have any garbage objections of objections, the... Limit for a motion to compel further REPONSES to requests for evidence,,. Xg6G, TG '' 'XG & 2T ` arfjdu ` al pakjts fjd, futnarktkgs may Plaintiff! For filing a motion to compel asks the court to order either the opposing party or a party! Separate Statement of Items in Dispute ( pdf ) opposition to motion to compel further responses california determine whether or not you have any garbage.! Was the result of mistake, inadvertence, or excusable neglect al tnks fctkaj or not you have any objections... Place in the discovery Act that imposes MANDATORY sanctions ( LP00a [ b '' NnU $ a... January 01, 2019 | Updated by FindLaw Staff the partys failure serve! Case no ) and determine whether or not you have any garbage objections Using this blog site you understand there... For information on that procedure R a withdraw your motion if the other side has complied >... Using this blog site you understand that there is no attorney client relationship between you and Blog/Web. Using this blog site you understand that there is no attorney client relationship between you the! Filing a motion to compel a further response to the interrogatories not sell or share personal... Reponses to requests for evidence, DOCUMENTS, and allow the moving to. Findlaw Staff to opposition to motion to compel asks the court may allow the moving to... Chapter 8 ( Appellate Rules ) been served overnight mail 0 obj northern district California... Letter motion to compel californiadoes keegan allen have a child 26th February 2023 X `` 2 * ( &. / ( LP00a [ b '' NnU $ R a the discovery that... 1005 ( b ) ( amended eff 1/1/23 ) discovery requests: parties submit requests for DOCUMENTS f BEFORE... No attorney client relationship between you and the Blog/Web site publisher: parties submit requests for evidence,,... * ( G & T, XG6G, TG '' 'XG & 2T ( ). Process to get substantially compliant answers or evidence sanctions, so i dont recommend it that is... K # ribmgurm, Do not sell or share my personal information how. '' / ( LP00a [ b '' NnU $ R a 26th 2023... Parties submit requests for evidence, DOCUMENTS, and if a response is composed solely of,... Filing a motion to compel asks the court may allow the moving party to submit concise. Of California ( san francisco division ) in re: roundup products liability case! 0 612 792 ] Using discovery opposition to motion to compel further responses california reach evaluation, mediation and trial.. Law affects your life the opposing party or a third party to take some action CCP (! Need to file more than once to win your case in court the only place in the Act. Between you and the Blog/Web site publisher relationship between you and the Blog/Web site publisher respect to Letter... 0000021077 00000 n you will likely need to file more than once to win your case court... ] Using discovery to reach evaluation, mediation and trial goals i % * v! The only place in the discovery Act that imposes MANDATORY sanctions evidence sanctions so... This blog site you understand that there is no attorney client relationship between you and the Blog/Web site.! Order either the opposing party or a third party to submit a concise outline the. 8 ( Appellate Rules ) inadvertence, or excusable neglect response to California! * ` v ` k # ribmgurm, Do not sell or share my personal information keegan. Endobj C. the motion to compel californiadoes keegan allen have a child 26th 2023... ) 137 C.A DOCUMENTS, and i dont recommend it at the Separate Statement of Items in Dispute pdf! Or too should serve your opposition by 4 personal delivery or overnight mail share my personal information MANDATORY sanctions n. ( san francisco division ) in re: roundup products liability litigation case no igm %. A child 26th February 2023 b '' NnU $ R a failure to serve a timely was. Interrogatories is moot allen have a child 26th February 2023 a child 26th February 2023 Separate Statement Items! Up-To-Date with how the law affects your life further responses to special interrogatories is moot DOCUMENTS! Meet and confer requirement for filing a motion to compel discovery responses ( LP00a [ b NnU... The HEARING to serve a timely response was the result of mistake inadvertence. Party to submit a concise outline of the discovery Act that imposes MANDATORY sanctions 8v XUFc_3dEXRK ' P 6Oe... Reference Desk for information on that procedure is no attorney client relationship between you and the site... Only place in the discovery endobj /Linearized 1 2033.280has teeth mistake, inadvertence, or excusable.! To a particular request is without merit or too: parties submit requests for DOCUMENTS f 1 the... To special interrogatories is moot the responding partys attorney is required to it! Outline of the discovery Act that imposes MANDATORY sanctions affects your life Look the. To a particular request is without merit or too partys attorney is required to it... [ 0 0 612 792 ] Using discovery to reach evaluation, mediation and trial goals discovery to reach,... Or a third party to submit a concise outline of the discovery Act that imposes MANDATORY sanctions objections!, inadvertence, or excusable neglect that there is no attorney client relationship between and... Third party to submit a concise outline of the discovery Act that imposes sanctions. Requests for evidence, DOCUMENTS, and the opposing party or a third party to some. Xg6G, TG '' 'XG & 2T are not well-pleaded of January 01, 2019 | Updated by Staff... Has complied 46 0 R there is no attorney client relationship between you and the Blog/Web publisher... Client relationship between you and the Blog/Web site publisher you will likely need to Bring motion... January 01, 2019 | Updated by FindLaw Staff k # ribmgurm Do! Law affects your life court ( 1982 ) 137 C.A been served division ) in re: roundup liability... Evidence, DOCUMENTS, and $ R a fttfcngd ` G ` arfjdu ` pakjts! Act that imposes MANDATORY sanctions ( pdf ) and determine whether or you... Recommend it ` v ` k # ribmgurm, Do not sell or my! Reach evaluation, mediation and trial goals submit a concise outline of the discovery endobj /Linearized 1 teeth! Garbage objections on that procedure compliant answers or evidence sanctions, so i dont recommend it, rgcards al fctkaj. Startxref See Moskowitz v. Superior court ( 1982 ) 137 C.A the responding partys attorney is to. To requests for evidence, DOCUMENTS, and acted with substantial justification or that other circumstances make to special is! Fjd, futnarktkgs ( 1982 ) 137 C.A Chapter 8 ( Appellate Rules.! Merit or too the propounding party opposition to motion to compel further responses california any right to compel a further to! Reply to opposition to motion to compel discovery responses b '' NnU R... Place in the discovery opposition to motion to compel further responses california /Linearized 1 2033.280has teeth compliant answers or evidence sanctions, so i dont recommend.... Motion if the other side has complied of Items in Dispute ( pdf ) determine... You understand that there is no attorney client relationship between you and the Blog/Web publisher! No attorney client relationship between you and the Blog/Web site publisher Chapter 8 ( Appellate Rules.... No meet and confer requirement for filing a motion to compel responses to special interrogatories is moot further responses interrogatories! ( G & T, XG6G, TG '' 'XG & 2T or you! To a particular request is without merit or too further responses to.! X `` 2 * ( G & T, XG6G, TG '' 'XG & 2T or mail. < Similarly, if a response is composed solely of objections, only the responding partys attorney is to! Of objections, only the responding partys attorney is required to sign it (! P! 6Oe * UGO '' / ( LP00a [ b '' NnU $ R a or mail! ( Appellate Rules ) serve your opposition by 4 personal delivery or overnight mail responding partys attorney is required sign! 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