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 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 the case can move forward and settlement discussions can be productive. Below are some of the many services I provide:

Case Management and Discovery Plans. I work with the parties in outlining the issues and creating 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 the parties so settlement discussions can be productive, and dispositive motions can be timely heard.

Tentative Rulings. Prior to the hearing, all parties will be served with a tentative ruling and will have time to notify the me and opposing counsel of their decision of whether to contest the tentative ruling. All motion procedures are set out in advance and are code compliant. Hearings will be held via Zoom 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. §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 the discovery they need to mediate the matter, have a dispositive motion heard and prepare for trial.