Timely, Thorough and Accurate Rulings

Discovery Referee

As the civil trial calendar overwhelms the trial courts with complex procedural and substantive issues, the courts have sought relief through references to "Discovery Referees" as permitted under California Code of Civil Procedure (C.C.P.) sections 638-645.2. The appointment of a Discovery Referee can be beneficial and cost-effective in complex litigation as these cases can involve issues of confidentiality and privilege and tend to be document intensive. When I am the Discovery Referee, I take a "hands-on" approach and actively manage the case by coordinating discovery and resolving discovery disputes so settlement discussions can be productive. Below are some of the many services I provide:

Case Management. Works with the parties in outlining the issues and coordinating a discovery plan. There will be scheduled hearing dates to coordinate discovery, to use as meet and confer sessions, as well as having discovery motions heard. I will work with the mediator and the settlement judge in directing discovery so settlement discussions can be productive.

Tentative Rulings. On the day prior to the hearing, all parties will be served with a tentative ruling and will have approximately three hours to notify the Discovery Referee of their decision of whether to contest the tentative ruling. All motion procedures are set out in advance and are code compliant.

Conference Call Hearings. Hearings may be held via phone or video conferencing. At any party's request, an in-person hearing can be scheduled and will be held at a mutually agreed upon-location.

Recommendation and Orders. I will prepare all the recommended orders which will contain a ruling on every objection to each interrogatory, request for admission, request for documents or deposition question in issue. In addition, there will be a ruling on sanctions and the apportionment of referee fees. The recommended order will also specifically state that if any party objects to the recommended order, they must comply with C.C.P. section 643.

On Stand-By For Depositions. With appropriate notice, I will be on phone standby to rule on objections during a deposition.

Aim Towards Settlement. I will assist the parties in obtaining an experienced professional to mediate the matter or work with the court to obtain an early settlement conference.