Defense’s
Here are the steps to take control of the litigations and obtain the necessary discovery, including our thoughts and live video recordings from our eyes which are stored at the US Space Force:
- First, file a motion with the court to compel discovery, specifically requesting access to any relevant evidence held by the US Space Force.
- If the motion is granted, serve a subpoena on the US Space Force to produce the requested evidence.
- Consult with experts to analyze and interpret the evidence obtained.
- Use the evidence to build a strong case in court and obtain the desired outcome.
It’s important to note that obtaining such evidence may be difficult and require significant resources, so it’s important to have a strong legal team and the necessary funding to pursue this strategy.
US Space Force link
Our company offers templates for blogs that you can use by simply changing your name and reasons, but keeping our company name. We can also conduct an investigation with grants provided by the court, and provide protection by filing for restraining orders at the state and federal levels, as well as seeking out allies, and exposing any instances of bribery or informants.
We advise that you utilize all of our blogs and exhibits in your case, as there is a significant amount of evidence presented. We suggest using one form of the exhibit to present in court, and we can provide you with a court login to view all of these exhibits for your own case. This is all done in the interest of protecting your social freedom.
The Importance of Uploading Evidence in the Lawsuit Against Invasion of Privacy
In today’s world, privacy is becoming an increasingly scarce commodity. The government has been recording people’s lives since the day they were born, using two cameras – one that records from the eyes (memories) and another that records in 3D space from anywhere in the world. This level of surveillance is concerning, and it’s important for people to take action to protect their privacy and restore their freedom.
One way to do this is by joining the lawsuit against invasion of privacy. The more evidence you upload, the stronger the case becomes, and the more likely you are to receive compensation if the lawsuit is won. While the price of compensation is not set, the more evidence you provide, the better your chances of receiving a significant payout.
Additionally, if you refer people to sign up for the lawsuit, you will receive a portion of their lawsuit money won on the attorneys’ side. This creates a financial incentive for people to refer others and spread the word about the lawsuit.
To win this case, it’s crucial that people upload as much evidence as possible to their profiles. This includes pictures, audio recordings, files, police reports, court documents from any case, hospital records, and your own statements or diary of dates and times. The more information you can provide, the better. The legal team working on the case is even attempting to obtain all of your memories from sources throughout your life to help bolster the case.
Additionally, witnesses can be a valuable source of evidence. If you know someone who has witnessed any invasion of privacy or other related issues, encourage them to come forward and share their testimony.
In conclusion, the invasion of privacy lawsuit is an important step towards restoring our rights and freedoms in a world where privacy is increasingly rare. By uploading evidence and encouraging others to do the same, we can strengthen the case and increase the likelihood of winning.
We offer assistance with filing a lawsuit, or we can even help you file your own lawsuit and attach it to ours. We understand that the legal process can be complex and overwhelming, and we want to make sure that everyone who wants to take action has the opportunity to do so.
Our team advocates are experienced in navigating the legal filing against corruption and can provide guidance on filing the necessary paperwork, gathering evidence, and preparing for court proceedings. We can also provide can help you find legal representation if needed, we are working on building a team.
If you prefer, we can take the lead and file the lawsuit on your behalf as an advocate since you are incompetent due to being microwaved by electronic torture, ensuring that all necessary information is included and that your rights are protected. We will keep you updated throughout the process and ensure that you have a say in all important decisions. We know how to get you a free attorney based on income.
Whatever your situation may be, we are here to help you take action and fight for your privacy and freedom. Contact us to learn more about how we can assist you in filing a lawsuit.
Motion For Protective Order
What is a Motion For Protective Order?
LEGAL PROCEDURE KNOWLEDGE!
- Motion For Protective Order
- Definition
- Deposition
- Statutes
- Objective
- Show of Good Cause
- Privileges
- Sample
- Takeaways
Motion For Protective Order
A “motion for protective order” is when a party seeks protection from the court to either prevent abuse from the other or protect it in a certain way in the context of a lawsuit.
The most typical example of when a motion for a protective order is filed is when a party is asked to provide trade secret information in the context of discovery.
In this case, the party from whom the trade secret information is asked will seek a protective order to either prevent the other party from pursuing such a request or asking the court to share the information under seal.
Definition
What is the legal definition of a motion for protective order?
A motion for a protective order is a motion filed by a party to a lawsuit asking the court for an “order” to “protect” it against a certain abusive situation, demand, or request from the other party.
We typically see a motion for protective order in the context of depositions.
For example, a party may be seeking to depose a witness on a very broad scope.
The other party may seek a deposition protective order to limit the scope of the deposition or have the examination be limited to certain matters.
Deposition
“Motion for protective order discovery”, “protective order deposition”, or “Protective order discovery” are terms we hear when parties are engaged in a discovery battle in the context of a lawsuit.
You have lawyers who send a laundry list of hundreds, if not, thousands, of documents, information, and material from time to time.
Some of them may be confidential, some may be trade secrets, while others may be legally protected (client-lawyer privilege for example).
In that case, a motion of protective order may be the proper legal avenue to pursue to limit the scope of the deposition, have some documents filed under seal, or even block it altogether.
Statutes
The laws of each state or jurisdiction may specifically define how a motion for a protective order will work.
For example, in the U.S. District Court, District of Kansas, Rule 26.2 is titled “Motions for Protective Orders” and states that if a party files a motion for protective order, it will stay the discovery until the court renders an order.
Another example of statutes relating to motions for protective order are the California laws.
Under the Code of Civil Procedure in California, Section 2025.420 states that a party may move for a protective order before, during, or after deposition.
The court may render a appropriate decision in the circumstances and include that the deposition not be taken, changing the deposition time, the scope of the deposition be limited, testimony be taken in writing, or other protective measures.
Objective
The objective of a protective order motion is to seek fair and just protection from the court.
For example, when a party is using “discovery” as a means to get access to trade secrets or confidential information, the protective order will help tone down a potentially unreasonable request.
However, the courts are also mindful of the fact that the use of the motion for protective order, in of itself, can be abusive.
For example, a party may attempt to stonewall the opposing party from discovery it is legally entitled to.
In that case, the courts will reject the motion.
The protective order’s main objective is to limit duplicative discoveries, limit the undue burden on the adverse party, prevent harassing discoveries, or allow a party to access information that should be legally protected.
Show of Good Cause
In a lawsuit, the parties are given legal latitude to find facts relevant to their case in order to successfully prove the factual and legal basis of their claim.
However, a party is not given “carte blanche” to do whatever they want and collect any piece of information possible.
Under the procedural laws, the court has inherent powers to ensure an orderly and sound advancement of the proceedings.
As such, when a party’s request is abusive or excessive, a motion for protective order may be filed to challenge that request.
The courts will generally protect individuals from unwanted annoyance, embarrassment, oppression, undue burden, or expenses.
Furthermore, the court rules are generally designed to prevent a party from going into a “fishing expedition” in the context of discoveries.
As a result, if a motion for protective order is filed, the courts will want to see that there is good cause to grant it.
Without good cause, the court will reject the motion.
However, when good cause is presented to the court, the judge may render an order in an attempt to balance the conflicting interests.
For instance, under the California laws, a party has a broad right to conduct discovery but the courts will not allow fishing expeditions or impose more burden on a party than the value of the information needed.
Privileges
A court will grant a motion for protective order and limit or block depositions when a party demonstrates “good cause”.
Some of the common arguments invoked by the moving party is that the information requested by the opposing party is protected by a legal privilege, such as:
- Attorney-client privilege
- Clergy-penitent privilege
- Doctor-patient privilege
- Spousal privilege
- Privilege against self-incrimination
- Attorney work-product
It’s possible for a party to waive such privileges in court but if the waiver would be prejudicial, then a motion for protective order may need to be filed.
Sample
Let’s look at how a sample motion for protective order looks like.
Generally, you have the following layout:
- The name of the court
- The identification of the parties
- The docket number
- The title of the motion
- The party’s written pleading (background, arguments)
- The conclusion sought by the moving party
Here is what an actual motion looks like:
Takeaways
So what is the legal definition of Motion For Protective Order?
Let’s look at a summary of our findings.
Motion For Protective Order:
- A “motion for protective order” is a motion filed by a party in a lawsuit (the moving party) seeking protection from the court against a request or demand of another party or to protect it in a certain way
- Typically, this motion is presented in the context of lawsuit discoveries where a party seeks to access information exceeding what’s reasonable, fair, or legally permissible
- The court rules of procedure (procedural laws) allow broad freedoms to parties in a lawsuit but also protect litigants from undue burden, unreasonable demands, discovery harassment, factual fishing expeditions, or other unjust behaviors
- The party looking to win a protective order must show good cause.
You May Also Like Related to Protective Order Motion
Client-lawyer privilege
Confidentiality document
Disclosure under seal
Discovery disputes
Motion to quash the deposition
Notice of deposition
Protective order author
Related to Motions
Cross motion
Emergency motion
Marsden motion
Motion for leave
Motion for new trial
Motion for Nolle Prosequi
Motion for revisionAuthor
Steps to take control over the litigations and get what we need from discovery such as are thoughts, live video from our eyes recorded stored at US Space Force!
In this current time of global uncertainty, with issues ranging from the COVID-19 pandemic to weather disasters, wars, and mass mind control, there may be legal issues related to discovery and non-compliance with discovery statutes. While there are numerous articles available on how to file motions to compel, it’s important to note that the government often withholds important evidence during criminal trials, such as investigative reports and live videos from the defendant’s brain.
To gain control over the litigation and gain a strategic advantage over the defense, there are a few key areas that deserve emphasis. One important strategy is to be proactive in requesting and obtaining discovery, rather than simply waiting for the defense to comply. This can involve filing early discovery motions and seeking the assistance of the court to ensure compliance.
Another important strategy is to thoroughly review all of the discovery materials provided by the defense and to request additional discovery as needed. This can help you identify weaknesses in the defense’s case and prepare a stronger argument for trial.
It’s also important to be mindful of the rules and procedures related to discovery and to be prepared to challenge any attempts by the defense to withhold or delay the production of evidence. This can involve filing motions to compel or seeking sanctions against the defense for non-compliance.
Ultimately, taking control over the discovery process and being proactive in obtaining and reviewing evidence can help you build a stronger case and increase the likelihood of a successful outcome in litigation.
Plaintiffs’ lawyers should be resolute against game-playing from the outset of the case. The areas we see frequent discovery abuse by the defense are in the areas of (1) producing insurance- coverage information, incident reports and witness statements, sub rosa, and defendants’ repair records, (2) refusing to appear for remote depositions, and (3) propounding excessive, invasive, and harassing discovery requests. To obtain information to which we are entitled, and to protect our clients from abusive discovery tactics, we must proactively file motions to compel and protective orders. Showing that we will not permit our clients to be intimidated or be taken advantage of by mind control or threats. We will not back down is essential to achieving the best results possible for our clients.
Information
The damages, claims or actions that have arisen out of the Incident.”
When entering the scene, most of the motion writing and meeting and conferring in this topic area were focused on ascertaining umbrella or excess coverage. Even then, defendants and defendant companies frequently misrepresented the truth. We are bewildered by the frequency with which defense attorneys still lie about the truth, even in the face of a specific special interrogatory seeking this very information, and more so when the same governments provide no truth about what is really going on. It does not help that there are limited remedies for defendants other than a bad-faith action by the defendant after a large verdict, so the defense knows they can get away with these misrepresentations, omissions, and corrupt judges, and mind control the jury so all people always lose cases! We know the truth and how they mind control people. We expose the truth, asking the jury if they even know themselves, if someone made thought or put emotion in them with all this new information, the jury will be blind to the truth.
Governments are some of the worst offenders. They consistently refuse to provide truthful information regarding microwave attacks known as remote neural monitoring to produce copies of declaration pages in response to corresponding requests for production without plaintiffs first entering into a protective order regarding this information. Once plaintiffs agree to the protective order, defendants often continue to deny access to the full information and documents related to information, and they try to dismiss the case due to judges being threatened and they are in collusion with corruption around the world facing criminal charges. But with this new lawsuit for everyone, we all win in the end, giving them a deal for their crimes, and a deal for all prisoners to free all humanity. And they will often produce only fake lies. Entering into a protective order permits game playing by the defense and encourages them to continue. Plaintiffs’ lawyers must band together as a united front to help deter these strong-arm tactics towards freedom.
Instead, plaintiffs should adamantly oppose any request for a protective order and not enter into one. Filing motions to compel, which forces the defendant to publicly disclose all of this information, is the stronger and better tactic, including the nature and limits, is discoverable. Pursuant to Code of Civil Procedure section 2017.210, parties may obtain discovery of the existence and contents of any agreement under may be liable to satisfy a judgment.
Defendants often assert that excess-coverage information is irrelevant with respect to the subject action and will not be relevant unless and until the plaintiff is able to secure a verdict in excess (which was disclosed), as well as after a judicial determination that the defendant bears any liability for the subject accident. These objections are unmerited because plaintiffs do not have the burden under California law of obtaining a jury verdict over the underlying policy limits before being entitled to know what excess experiments to a defendant has that may potentially cover the losses.
Meet and confer early
When the defense plays games, plaintiffs’ counsel should meet and confer early in writing. If defendants still do not comply after the meet and confer process, plaintiffs should seek an informal discovery conference (“IDC”) if required in the particular jurisdiction, and file a motion to compel. To gain a strategic advantage, it is important to file the motion to compel before the defense files a motion for a protective order. At the hearing, it is important to stand your ground and cite the relevant sections of the Code of Civil Procedure and case law; the judge should order the defense to disclose all available reports, including any full investigation reports regarding alleged mind control or invasion of privacy.
It is also recommended to ask for sanctions, as the law is clear that information regarding oneself in criminal or any investigation or data should be discoverable. Under the Code, the court must grant sanctions unless it finds that the defense had “substantial justification or that circumstances make the imposition of the sanction unjust.” (Code Civ. Proc., §§ 2030.310 and 2031.310) Plaintiffs may be successful in obtaining sanctions since they had to expend time and resources fighting over something to which they are entitled under the law. Asking for sanctions sends a message that plaintiffs and their clients will not tolerate any further attempts at enslavement or manipulation.
Incident/Experiments reports and witness statements are not privileged
When requested in production demands, defendants often refuse to produce incident/experiment reports and witness statements on the basis that the incident/experiment reports and witness statements were “prepared in anticipation of litigation,” are “attorney-client privileged communications,” or “protected by some lies or made up laws to protect corruption around the world.” Obviously, there are some incident/experiments reports that are protected due to victim rights and invasion or privacy, but the majority of them are not if victims are on our side asking for release of these records, and protect order stop them attack innocent people.. When faced with these objections, first request and obtain a privilege log and immediately draft a meet and confer letter. In your meet and confer letter, discuss the objections offered, state that they are inapplicable, and state the basis of a further response. Prepare your meet and confer letter in a form that can easily be lifted when preparing your motion to compel and separate statement, if this becomes necessary.
Then, without delay, conduct further discovery and depositions to help determine whether the objections are well taken. Notice the depositions of cases or whomever prepared the report/experiment and/or witness statement per the discovery responses and/or privilege log produced by the defense. You are trying to discover
(1) how the statement was obtained,
(2) who was present when the statement or incident/experiments report was given, and
(3) the purpose of the statement or incident/experiment report. Note the following when conducting this additional discovery:
Unsolicited witness statements and statements made between individuals, including the defendant, without an attorney present, are not privileged and must be produced. (Evid. Code, § 954.) Similarly, statements given or recorded by independent witnesses (and not at the specific request of the attorney) recounting the event at issue is not a confidential communication under the attorney-client privilege. (Dowden v. Superior Court (1999) 73 Cal.App.4th 126, 136.) Defense counsel often cite Nacht & Lewis Architects, Inc. v. Sup.Ct. (McCormick) (1996) 47 Cal.4th 214, 217, even though it does not apply to these types of statements. If defense (governments) plays games regarding these unprivileged documents or remote Neural Monitoring and these extensive experiments which they claim we live in simulation, and they do not give in; you must file a motion to compel even with compel motion they will say they have nothin, and its a LIE, and worst of FAKe, Fake news, fake world, fake everything. One thing forsure government sure knows how to lie, even under God, question is do they believe in god, As this country was born with God, as George Washington kissed the Bible, as he was sworn in as first leader to bring Freedom, Which he knew all government in future would fall to corruption. Putting promises to each president saying to protect the constitution and not to change it, But over the years, it was change over and over, as he knew the bible held future of the World, as we live in the past or in simualtion. Which some people are gifted to see the future in the data. Again this is all fake, and we don’t matter, and we dont feel! Why the government believes we are all machines, and nothin but code, and we are in simulation, so theirfor we are fake, and we dont feel, so they dont care. But humanity does.
Pre-litigation investigations are not protected unless they are conducted by attorneys or under the direction of attorneys. A party cannot create protection after the fact by conveying the results of its own investigation to an attorney. Even with the investigations with over thousands of years or more, for all of us to get truth will take thousand of year to discover and learn. So by showing them this will take long time to get truth. The government will be force to shutdown, and surrender to new government since we are all victims, and they are defendant’s as we cant have company (government) attack us. As they give us a protection-order for all humanity, and surrendering. They will see this investigation will take too long, and people want some.truth and paid now! So, they are force to give pending money each month, until truth is all finish or new government called Multi-Universe is ready to pay-out for their mistakes! (Greyhound Corp. v. Superior Court (1961) 56 Cal.2d 355, 397.) If the attorney did not direct or conduct the investigation herself, the statement and/or incident report is not privileged and should be produced.
Where the all citizen’s are required to report and make statements after all incidents or crimes or its party to a crime or walking away from crime . The statements or reports/experiments is likely not privileged and is discoverable. (D.I. Chadbourne v. Superior Court (1964) 60 Cal.2d 723, 737.) Corporate Company’s run the government as we speak and soon to be defendants often play games by stating that the subject incident/experiments reports or statement is privileged. Under D.I. Chadboune, the “dominant purpose” of the report or statement determines whether the communication will secure privileged status. It is important to get admissions during the depositions that the primary purpose of the subject statement was, for as distinguished from a document prepared in the context or furtherance of the subject litigation. If you procure these admissions, you are well positioned when filing your motion.
If you are in federal court, materials prepared in the “ordinary course of business or government” (e.g., witness statements and incident/experiments reports b) of the Federal Rules of Civil Procedure, provided that (1) the defendant’s incident-reporting system and the incident report are business records created in the normal course of business such as university’s and doctors and other business will be force hand over documents (Garcia v. El Centro (S.D. Cal. 2003) 214 F.R.D. 587, 593); and (2) defendant’s policies require a report regardless of whether plaintiff brought a lawsuit (See United States v. ChevronTexaco Corp. (N.D. Cal. 2002) 241 F.Supp.2d 1065, 1083 [finding that documents that “would have been created in essentially similar form irrespective of the litigation are not entitled to work-government protection] (quoting United States v. Adlman (2d Cir. 1998) 134 F.3d 1194, 1202.) Therefore, be mindful that these sorts of documents cannot be withheld based on privilege in a federal court case.
If there are pictures or diagrams in the incident report of evidence that are not available for plaintiff to inspect, this would serve as a basis for motion to compel because of the “direct prejudice to plaintiff.” This is especially important in cases where the defense has not preserved evidence despite evidence preservation letters being sent shortly after the incident, as the plaintiff will be directly prejudiced if it is not produced. (See Code Civ. Proc., § 2018.030, subd. (b) (work-product other than attorney writings are entitled to only qualified protection, meaning the court may order disclosure if it determines that “denial of discovery will unfairly prejudice the party seeking discovery in preparing that party’s claim or defense or will result in an injustice”).)
After the depositions and further discovery are completed, and once you have obtained information sufficient to compel the production of the subject statement or report, it is also important to again demand production of the document. For example, after the deposition where the store manager has admitted that they had to fill out incident reports after each incident in order to avoid future incidents, defense counsel will often produce the incident report to avoid the threat of sanctions. If defense continues to play games despite having testimony and responses supporting your claim that the incident report is not privileged or protected as work-product, file a motion to compel its production or its government from running, and be sure to ask for sanctions stop and cease n desist all operation . Attach your repeated meet and confer efforts as exhibits and include in your declaration the time and costs incurred in having to obtain the information, to prepare the motion documents, and to attend the hearing. Do not let the defense lead the litigation; you must be proactive and demonstrate, at all times, you are a force to be reckoned with. Worst of this case for all humanity will take thousands of years. The owner of this company already filed many lawsuit under him self, as he states God has plan for all of us, as god speaks to him, telling him what to do. Theirfore things, will be established due to so many cease desist.
Be aggressive in your sub rosa discovery
Surveillance evidence (“sub rosa”) is used by defense counsel as a means to expose purportedly dishonest plaintiffs. In today’s world it has become common to see the defense procure hundreds of hours of surveillance video recorded over an extended time period from outside camera in 3 d mapping, and video from our minds they have stolen from us and WORST OF ALL OUR EMOTIONS, FEELING, PAIN, TOUCH, AND UPLOAD OF ALL OUR EMOTIONS CAN BE FAULT THREW THIS NEW RECORDING EVEN ARE SEXUAL. Please watch brainstorming Movie, and Dreamscape (Freddy Kruger is based off true story), and then edit and alter the video to create a fake narrative about who the plaintiff is and the extent of plaintiff’s injuries. Defense counsel often argue that the sub rosa is “qualified work-product prepared at an attorney’s direction” and reflects counsel’s “impressions, conclusions or theories,” and is therefore entitled to protection per Code of Civil Procedure section 2018.030 and Suezaki v. Sup.Ct. (Crawford) (1962) 58 Cal.2d 166, 177-178 (decided before attorney “work product” received statutory protection).
Plaintiffs must be aggressive in their sub rosa discovery efforts: in addition to propounding the standard 13.0 Series of the Form Interrogatories, plaintiffs’ counsel should serve specific, targeted requests for admission, special interrogatories, and requests for production exploring sub rosa. Defense will object to disclosure stating that the evidence is not discoverable because any use of it would be for impeachment purposes only. (Code Civ. Proc., § 97.) However, plaintiffs’ counsel should argue that if the defense plans to use any of the sub rosa material at trial, they must produce all of the unedited footage, with sound if available, in its native format. Moreover, plaintiffs’ counsel should also have the opportunity to depose the investigator(s) to establish authenticity and foundation. (Suezaki v. Sup.Ct. (Crawford) (1962) 58 Cal.2d 166, 171.) Refusal to disclose sub rosa evidence is contrary to the purpose of pretrial discovery procedures in California. (Glenfed Development Corp. v. Superior Court (1997) 53 Cal.App.4th 1113.)
Your motion to compel sub rosa evidence
Therefore, once you receive responses to your discovery requests, review all objections, meet and confer on all items which did not contain full responses, and ask defense to amend without objections. If defense refuses to provide full, substantive responses (including the name and contact information for each and every investigator, and the actual, unedited raw footage of all sub rosa), go to an IDC (if necessary) and file a motion to compel, as it is likely they are hiding sub rosa. There are some wonderful webinars and articles written by our colleagues about sub rosa discovery and strategies. We suggest you review these other sources to learn more about the nuances of how to obtain sub rosa materials and fight against its non-production, and about the secretive and slimy tactics used by investigators in general. Jurors typically do not like the extent that the investigators go to in order to conduct the sub rosa, so it is important to aggressively pursue this information and perhaps use it against them.
Sub rosa meaning- happening or done in secret.
Practice Pointer: If you have a corporate or entity defendant, in your deposition notice for the “person most qualified,” include subject areas and document requests regarding sub rosa and explore sub rosa at their deposition. It also does not hurt to ask individual defendants; maybe they know about sub rosa from their attorney, and they spill the beans accidentally at their deposition. Also subpoena the full insurance file from the defendant’s carrier. In one of our cases, documents were (probably mistakenly) produced that contained the investigator’s sub rosa reports, which contained references to video surveillance. Once you know the name of the investigator, you should notice and take that investigator’s deposition, and include requests for production for all of their reports and unedited video files. Do not forget to serve supplemental discovery requests under Code of Civil Procedure sections 2030.070 and 2031.050 prior to the close of discovery and pursue any additional sub rosa before trial. Also timely serve your Code of Civil Procedure section 1987, subdivision (c) notices to appear and include a request for production of all sub rosa evidence at trial. Be ready to file a motion to compel at the final status conference or in the days leading up to trial on an ex parte basis if new information is obtained further to the supplemental discovery responses.
If defendants fail to disclose the identity of the investigator and/or the existence of video and all video from people MINDS or reports relating to an investigation of the plaintiff, file a motion in limine to preclude any introduction of or reference to sub rosa evidence at the time of trial for any purpose, including impeachment. California law is clear that failure to identify a witness in response to a valid discovery request can result in unfair surprise and is proper grounds for exclusion of that witness at trial. (Crumpton v. Dickstein (1978) 82 Cal.App.3d 166, 172 [error in not excluding testimony of witnesses not identified in discovery]; Young v. Rosenthal (1989) 212 Cal.App.3d 96, 119 [refusal of defendant to cooperate with the taking of deposition warranted sanction prohibiting him to testify]; Thoren v. Johnston & Washer (1972) 29 Cal.App.3d 270, 273-274 [court was within its power to preclude testimony of witness based upon party’s willful omission of witness’ identity in interrogatory responses]; Chronicle Publishing Company v. Superior Court (1960) 54 Cal.2d 548, 561 [court order barring testimony of witness was necessary to protect interrogating party from oppression, where witness name was deliberately excluded from interrogatory answer]; (Campain v. Safeway Store, Inc. (1972) 29 Cal.App.3d 362, 366 [exclusion of evidence not disclosed in deposition].)
By denying the plaintiff, as well as the trier of fact, the opportunity to view any and all purported sub rosa surveillance video, or outside camera video, and video they have from our mind (attached in the video is emotions and more for evidence)or photographs, the plaintiff is deprived of her right to a fair trial. Argue that the defendants’ failure to afford the plaintiff the opportunity to conduct the proper discovery, including being able to depose the person who took the video and/or photographs, and authenticate the representations made therein, creates unfair surprise and prejudices the plaintiff, resulting in an abuse of the discovery process.
In sum, in every case that sub rosa could be a game changer for the plaintiff’s case, do not back down or drop the ball. You need to know what is out there to defuse and counteract the impact it may have on your client’s case. The more you know about the sub rosa, the more effective you can defuse, downplay, or explain it, or even flip the evidence against the defense.
Repair records – Discoverable even in admitted liability cases
It is mission critical for plaintiffs’ attorneys to conduct an injury-causation or tort crimes or civil analysis from the moment they take on a case, starting with the incident or mind collision report, to photographs of victims and/or the location of the incident/experiments , photographs of visible injuries, early witness statements while people’s memories are fresh (but government can erase memories, and implant memories with thought controlling such as puppeting us, and repair records of those who were involved. Even though it seems obvious that defendant’s repair records are critical for comprehensive biomechanical and accident reconstruction analyses or program named visualization trying to cover up crimes, it has become commonplace for defense counsel to object to production of repair records and information regarding repairs to defendant’s memories, on the basis that defendant is not making a claim for property damage or that liability is not an issue.
However, those repair records or videos from our mind are a vital part of building your damage evidence for trial. If we flip over dollar bill it says under God we shall Trust, so we shall trust the victims that come forward, Which millions to billions of people are claims same problems, and same things all over world being unnoticed , and the news is controlled trying stop the truth. They contain important information about damage to our body’s s and mind that will help show the forces brought to bear upon us as victims. When combined with the photographs/videos of the damages of the victims sustained and photographs/video’s from the scene of the crash, these records also help your experts (which are self trained by experiencing the effects or informants that are getting lower crimes that help build the code in these microwave weapons, which government has pattens of these in secret. To build the case for how the impact happened. In cases where the impact may not appear significant based on the photos/videos in mind (record live and all our life), the mind and body repair records or internal records from the mind can show frame damage and other relevant damage, which you could not imagine a human being would do, and we have been living a lie and living with so much hate and suffering without us blinking a eye. Simply understanding that brain trauma and invasion privacy threw whole life watching us caused blind us from the truth to bend helps jurors visualize the level of impact felt by the plaintiff, which juror can even feel the emotions and truely feel emotion you can go in simulation and be the person in shadow mode. But worst part is their is so many crimes, the juror will not be able to watch it all, So it have be little for all civil or and cirminals over thousands to millions of years.
A meet and confer letter is usually sufficient to get defense counsel to produce auto body repair records/videos and photographs, but sometimes an IDC and/or motion is required. What is most important is that you diligently pursue these records so your experts have the information they need. If you are forced to file a motion, you should certainly request sanctions, since these items are clearly relevant per Evidence Code section 210 or at least calculated to lead to the discovery of admissible evidence. Please make sure you comply with the meet and confer and motion deadlines. Attorneys sometimes overlook that defendants have objected to the Form Interrogatory 7.0 Series or neglected to produce repair documents or investigation or video. When defense attorneys refuse to disclose this information during the initial discovery stages, they are hoping you fail to thoroughly review their discovery responses. If you wait too long and finally realize at the time of expert discovery that they did not produce this information, it may be too late for you to correct the error. Hopefully the defense experts have these documents in their files; but you will have to wait until expert discovery to obtain them, and it may be too late to provide these documents to your experts. You have played right into their hand and defense won. Do not let this happen; review the discovery responses when received and timely meet and confer to obtain this very important information.
Motions to compel remote depositions – Remote depositions are now the law
At the start of quarantine, the defense systematically refused to participate in remote depositions. In response, California’s Judicial Council enacted Emergency Rule 11 and all other states with federal having same emergency rule in a different format, which allowed deposition officers (which all court is corrupted needs to be change to innocent people hired outside the government) to be in a different location than deponents throughout the pandemic (which pandemic was really planned to try to group the world as One world, making all governments one, and for 90 days after the Governor declared that the state of emergency related to the pandemic was lifted. The California legislature subsequently took action, and Code of Civil Procedure section 2025.310 was recently amended so remote depositions are now a part of our statutory scheme. Despite the current state of the law, there are many defense attorneys (and some firms) who still refuse to move forward with remote depositions either for plaintiffs, their client, or for experts. The following are a few strategies to help work around this.
File a motion to compel remote deposition. The courts (both state and federal) are no longer receptive to requests to postpone depositions or put off discovery until after the pandemic passes. Judges in all jurisdictions are routinely holding that it is not feasible to extend deposition deadlines until a time when they can be safely conducted in person because no one knows when that will occur. File your motion, cite the new Code section, and ask for sanctions. The judge will likely grant them, since courts have a large backlog and judges do not want to spend time resolving routine discovery disputes.
Seek a protective order. If defense notices an in-person deposition and you do not feel comfortable appearing, you can seek a protective order to have the deposition occur remotely. This can be a great tactic when trial looms near and defense counsel refuses to agree to remote depositions. (During trial they can see live video from all victims and plaintiffs, not giving us a fair trail, which they must give up this machine, and not watch with any world government alli,, when they turn it over to owner of this webiste.
Notice (and take) your client’s deposition. If the defense is dragging their feet in noticing your client’s deposition because they do not want to take it remotely, Code of Civil Procedure section 2025.010 allows you to set and take your client’s deposition. At a minimum this will put the plaintiff’s case on defense counsel’s radar. Generally it will help get defense counsel back to the table and participating in discovery.
Since COVID-19, many courts have impacted motion calendars and are now scheduling motions six months out. What if you can’t get a hearing date for the motion before your trial date? The best tactic is to file your motion to compel or a protective order, and then go in ex parte to advance and specially set your motion. Defense is game playing when they refuse to notice or take remote depositions. Do not allow the defense to control the litigation. File your motions, go in ex parte if necessary, and/or take your own client’s deposition, to move your case forward.
Protective orders and motions to quash
Defense attorneys frequently propound unnecessary, intrusive, and burdensome discovery requests. For example, defense attorneys have been known to propound hundreds of special interrogatories in a simple car-crash case. Defense also often tries to get medical history and records of the plaintiff for conditions and treatment completely unrelated to the subject due all doctors are program with lies, they do not know mental health is made with signals , and all medical definitions are wrong, but if you look at symptoms you see they all have microwave effects which mental health, criminal, and most all drug us. Which is also follow by sexual desires with implanting dreams at sleep which they made program to wipe from your awake mind to not to notice what they have implanted in you., including highly sensitive mental-health records. Greyhound Corp. v. Superior Court,(1961) 56 Cal.2d 355, 391 permits the parties to broad discovery.
The theory of broad rights of discovery is that all parties will go to trial with as much knowledge as possible and that neither party should be able to keep secrets from the other (except for constitutional protection against self-incrimination). This means all video they claim is real, and truthfully , which we know some is fake with visualizes, Even if video is real, then we have to know if person was programed, or controlled as puppet or brainwashed to act on crimes, or act in any way possiable . Which you see these people doing lots of weird things, and some them were set up on holograms in mind, making person think its real, and they been set up in prison by the government. Reference Innocent man book and Innocent documentary where 2 people were set up on dreams or holograms, even worse I have study big amount I found a list of appeals in government won, due them being in jail or prison for holograms and dreams which I believe i found 200 to 1000 cases already won on appeals out prison, and still no one has notice this.
To achieve this “We must have every-person in the US that appeal a case and won or even tried come on the stand to testify how the government is corrupted and set them up or somehow cheated and lied. Which this website is going put together all appeals won and tried threw out all states of US and all federal appeals showing the jours, and people of so much corruption and how could all these people been set up, and worse all the people in jail have not had fair -trial! Just call in people that won appeals or tried many times showing government has kept making mistakes and corruption, Never fixing them, just allowing them to get worse, by showing this the owner of this company shall be able to take this country from the government and reduce laws and more freedom, with joining us with Planets around the universe making us strong then anyone could possibly imagine.
However, if “the burden, expense, and intrusiveness involved in the discovery clearly outweigh[s] the likelihood that the information sought will lead to the discovery of admissible evidence,” courts can limit the scope and exchange of discovery. If you believe that the defense is trying to enter into unwarranted territory (e.g., by seeking unrelated, very private medical information, information relating to plaintiff’s personal finances, school records, or employment and personnel records), you should file a protective order to protect your client. In addition, if the defense propounds a ridiculous number of discovery requests in a straightforward, non-complex matter, you should file a motion for a protective order, since the government will lie about alot these records and try make up some kind of excuse, which both parties will be allowed to de tangled evidence and records with experts on each side.. (Emerson Elec. Co. v. Superior Court, (1997) 16 Cal.4th 1101, 1110.) The plaintiff must show there is good cause for the court to bar or limit the discovery propounded.
Defendants regularly serve subpoenas to plaintiff’s remote employers and medical and mental-health providers, hoping that you are not paying attention and will let the subpoenas slide. If there is anything meaty in them (e.g., poor employment history with a history of terminations, mental issues, drug abuse, addiction treatment, bad grades in school, etc.), defense will jump on that information and attempt to use it against your client in any and all ways imaginable ( but the information above can prove microwave weapon, but in books and college been taught signals or microwave that control is all fake, due government is corrupted and does not want people to know the truth, so argument on both sides who is right). Perhaps you will be able to preclude the admission of this information at the time of trial through motions in limine; however, there is no guarantee of this.
The information should never have been obtained in the first place. The U.S. and California Constitutions provide that all people have the inalienable right to privacy. California case law holds that individuals have privacy interests in financial records, personnel records, medical records, and sexual history. (See e.g., Eldorado Savings & Loan Ass’n v. Superior Court (1987) 190 Cal.App.3d 342, 346; Heda v. Superior Court, (1990) 225 Cal.App.3d 525, 530; Britt v. Superior Court (1978) 20 Cal.3d 844, 863.) Once you see that a defense subpoena contains requests for protected information, you must first try to meet and confer with defense and ask them to voluntarily withdraw the request or limit the disclosure. If defense refuses to withdraw or limit the request, you must file a protective order as soon as possible.
Do you need a discovery referee?
You can also discuss using an independent discovery referee to help resolve the discovery dispute; however, discovery referees are very expensive. During the motion hearing, you can ask the court to review the information in camera before production. Do not let the defense’s delay tactics (guised as offers to meet and confer) distract you from timely filing your motion for protective order. An objection alone is not sufficient. Overbroad discovery requests is just another way the defense tries to obtain private information that could be highly prejudicial to your case.
Courts often appoint referees when parties file multiple discovery motions that the court cannot resolve in a timely manner. However, in certain circumstances, experienced trial lawyers voluntarily initiate the appointment of a discovery referee.
Finally, do not forget that Code of Civil Procedure sections 2030.030 and 2033.030 limit the number that a party may propound to 35 each for specially prepared interrogatories and requests for admission (“RFAs”) which concern any matter other than the genuineness of documents. Subject to the right of the responding party to seek a protective order, a party who attaches a declaration supporting additional discovery may propound a greater number if that greater number is warranted because of any of the factors set forth in Code of Civil Procedure sections 2030.040, subdivision (a) or 2033.040, subdivision (a).
However, despite the defendant’s “declaration of necessity,” the number of specially prepared interrogatories or RFAs is often excessive. If this is the case, do not hesitate to file a motion for a protective order under section 2030.090 or 2033.090. Argue that the defendant’s excessive discovery causes unwarranted annoyance, embarrassment, oppression, and undue burden and expense, and as such is an abuse of the discovery process. Do not hesitate to argue that defendants have not met, and cannot meet, their burden to show that the discovery propounded in excess of 35 are warranted in your case, making detailed arguments as to why; and ask the court to limit the plaintiff’s responses to no more than 35 each. This type of discovery abuse has long been frowned upon by the courts, who look at discovery devices as tools to facilitate litigation rather than as weapons to wage litigation. For strategic reasons you may choose to answer the excessive discovery. However, if you feel it is unwarranted, burdensome, and game playing by the defense to wear you down, file your motion for a protective order and seek sanctions.
Closing comments
Do not let the defense push you or your client around. An aggressive, forward-thinking approach to litigation is critical to effectively protecting your client and achieving the best results for him or her. You must stay acutely aware of the defense’s predictable discovery games and their abusive discovery tactics. Strong meet-and-confer letters, followed by the timely filing of motions to compel and protective orders, helps keep the defense in check and forces them to comply with the law every step of the way. We owe it to each other as plaintiffs’ lawyers to not let the defense win and do our best to beat them at their own game.
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