Notwithstanding the outcome of the particular discovery motion, the court shall impose a monetary sanction ordering that any party or CCP 128.7(c)(1). Rptr. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-128-7.html. (Subd (a) amended effective January 1, 2004; adopted effective July 1, 2001.). The California Legislature explained that an action or tactic is considered frivolous if it is, totally and completely without merit or for the sole purpose of harassing an opposing party. (CCP 128.5 (b) (2)) The burden to prove that an action or tactic was frivolous is on the party filing the motion for sanctions. (b)(4).) (3)The allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery. For authorities updated in real time, please see the SmartRules Guide for the litigation document you are drafting. On April 19, the day after payment was due, the Sugasawaras' attorney filed a declaration that the money was not paid. (b)The court may impose an issue sanction ordering that designated facts shall be taken as established in the action in accordance with the claim of the party adversely affected by the misuse of the discovery process. To provide accurate legal advice, additional facts and research may be necessary. The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party after the motion was filed. App. Finding willful failure, the trial court ordered that defendant's answer be stricken and its default entered. (b). Copyright 2023, Thomson Reuters. 631] [court "should not deprive a party of all right to defend an action if the discriminating imposition of a lesser sanction will serve to protect the legitimate interests of the party harmed by the failure to provide discovery"].). The California Chamber of Commerce is encouraging its members to send letters to California Governor Gavin Newsom urging him to veto California SB 707, which was passed by the states Assembly and Senate and is currently sitting on his desk awaiting his signature. by affidavit. An order imposing sanctions must be in writing and must recite in detail the conduct or circumstances justifying the order. Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. On November 1, 1994, counsel for the Sugasawaras again moved the court to strike Newland's answer, this time because he had not "paid the sanctions that were ordered by the Court upon the striking of the Answer, or upon granting relief from default, as affirmed by the Court of Appeal." A defendant's failure to produce subpoenaed documents did not relieve the plaintiff of the obligation to make a prima facie case. (188 Cal.App.2d at p. Aside from the other infirmity of the order, the sanction subjected Newland to a judgment in excess of $220,000 and foreclosed his entire defense, including consideration of his then pending motion for summary judgment, because he was three days late in paying the monetary sanction he owed. Filing 501. Start with your legal issue to find the right lawyer for you. App. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. If imposed solely for failure to obey a court order, without evidence of bad faith or no merit, sanctions imposed under sub. If a failure to comply with an applicable rule is the responsibility of counsel and not of the party, any penalty must be imposed on counsel and must not adversely affect the party's cause of action or defense thereto. Of the 32 states, 29 stipulate similar penalties, although in practice sentences were often more lenient. whether a party seeking sanctions has exercised due diligence. (C) Direct the attorney, law firm, party, witness, or other person to show cause why sanctions should not be imposed for violation of the rule. WebContempt and Monetary Sanctions. As we have explained, a terminating sanction issued solely because of a failure to pay a monetary discovery sanction is never justified. 1985) Appeal, 678, p. that appears to violate subdivision (b) and directing an attorney, law firm, or party The court explained: "While under the statute the court undoubtedly has the power to impose a sanction which will accomplish the purpose of discovery, when its order goes beyond that and denies a party any right to defend the action or to present evidence upon issues of fact which are entirely unaffected by the discovery procedure before it, it not only abuses its discretion but deprives the recalcitrant party of due process of law. Ficamos muito satisfeitos., A Perfect Design tem um excelente atendimento, os custos e benefcios de seus materiais so perfeitos, j que o preo acessvel. Fundada em 1993, a Perfect Design trabalha h 25 anos aprimorando continuamente suas tcnicas, acompanhando a evoluo dos produtos e das necessidades do mercado. The court continued the motion to strike to that date, and set a mandatory settlement conference (MSC) to be held on the same day. https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2023-030/, Read this complete California Code, Code of Civil Procedure - CCP 2023.030 on Westlaw. Sanctions for failure to provide discovery. Rptr. In determining what sanctions, if any, should be ordered, the court shall consider whether a party seeking sanctions has exercised due diligence. (Subd (c) amended effective January 1, 2007; adopted effective July 1, 2001; previously amended effective January 1, 2004.). App. Code of Civil Procedure 128.7 does not apply to discovery documents including requests, responses, objections and discovery motions. following conditions are met: (1) It is not being presented primarily for an improper purpose, such as to harass Rptr. The court on its own motion may issue an order to show cause that must (1) state the applicable rule that has been violated, (2) describe the specific conduct that appears to have violated the rule, and (3) direct the attorney, law firm, party, witness, or other person to show cause why sanctions should not be imposed against them for violation of the rule. Ultimamente tem sido difcil encontrar fornecedores assim., Queria agradecer a parceira e a qualidade do produtos de vocs, os cordes so lindos e exatamente como combinamos, todos amaram! Each paper shall state the signer's address and telephone number, if any. App. 3d 664, 670 [157 Cal. Contempt and Monetary Sanctions. Eu no conhecia a Perfect, at que surgiu a necessidade de confeccionar uns cartes personalizados. (c) If, after notice and a reasonable opportunity to respond, the court determines Newland's attorney thought his agreement with counsel for the Sugasawaras also postponed the date for payment of the sanctions ordered against his client (which, by then, amounted to $750) to April 21, although no order postponing payment had been made. Because of that, an order terminating a plaintiff's lawsuit or striking a defendant's answer and entering its default (in effect, terminating sanctions) solely because of failure to pay the monetary sanction is excessive. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. Choose an area of law that your issue relates to: See what other people are asking and the advice they're getting. God I don't want to pay any if the sanctioned party wins and is awarded fees, the judge may net out the amount of fees awarded to each side when calculating a final judgment. was convicted of a felony, and that the plaintiff is guilty of fraud, oppression, This sanctions rule applies to any action or proceeding brought under the Family Code. Stay up-to-date with how the law affects your life. (g)This section shall not apply to disclosures and discovery requests, responses, objections, and motions. (d)A sanction imposed for violation of subdivision (b) shall be limited to what is sufficient to deter repetition of this conduct or comparable conduct by others similarly situated. That would be a separate document with special language that makes it a final judgment. Stay up-to-date with how the law affects your life. Current as of January 01, 2019 | Updated by FindLaw Staff. its order to show cause before a voluntary dismissal or settlement of the claims made An attorneys duty of candor includes the duty not to make material misrepresentations to a court. (The statutory formula, stated in section 2023 and repeated throughout the discovery method sections of the act, is that the trial court "shall" impose a monetary sanction "unless it finds that the one subject to the sanction acted [40 Cal. 4th 611]. Second Dist., Div. so identified, are reasonably based on a lack of information or belief. The usual notice period required by Code of Civil Procedure 1005(b) applies after the twenty-one (21) day wait has expired. Failure to Meet and Confer. upon a motion for contempt to enforce the order, maybe losing the law suit and judgment against the offending party. JEFFREY M. NEWLAND, Petitioner, v. THE SUPERIOR COURT OF LOS ANGELES COUNTY, Respondent; JIM Y. SUGASAWARA et al., Real Parties in Interest. ), [2] [1b] The rule that a sanction order cannot go further than is necessary to accomplish the purpose of discovery is some 35 years old in California, and is rooted in constitutional due process. The authorities cited in this At A Glance Guide are current as of the publication date. Ser empresa lder no mercado, reconhecida pela excelncia em solues no seu segmento. (b) By presenting to the court, whether by signing, filing, submitting, or later advocating, If warranted, the court may award to the party prevailing on the motion the reasonable The next subdivision provides a list of sanctions in graduated severity, beginning with monetary awards and ending with terminating orders. In Jones v. Otero (1984) 156 Cal. Subject to the limitations in paragraphs (1) and (2), the sanction may consist of, Conduct 3.3) In Levine et al. existing law or the establishment of new law. 651.). Caryl Richards was a products liability case in which the defendant failed to adequately respond to discovery about the chemical properties of its product even after being ordered to do so. There are two penalty provisions in the California Labor Code: 4650 penalties of 10% for overdue 602] [distinguishing among provisions that required only "failure or refusal" and those requiring "willful failure"]; cf. Notice of motion shall be served as provided in Section 1010, but shall not be filed with or presented to the court unless, within 21 days after However, most awards of attorney fees simply say the fees are awarded and do not set a time for payment or constitute a judgment. or, if imposed on motion and warranted for effective deterrence, an order directing (i)This section shall apply to a complaint or petition filed on or after January 1, 1995, and any other pleading, written notice of motion, or other similar paper filed in that matter. B094760. Get free summaries of new California Court of Appeal opinions delivered to your inbox! A motion for sanctions must be served twenty-one (21) days before it is filed. Sanctions for violations of rules of court in family law cases. CCP 128.7(d). Often, the judge prefers to wait until the end of the case. App. %%EOF 4th 615] reasonably related to the purpose of effecting the discovery due." Nov 27, 1995. CCP 128.7(g). [See 917.1, subds. Curitiba-PR. Sanctions must not be imposed under this rule except on a request for order by the person seeking sanctions or on the court's own motion after the court has provided notice and an opportunity to be heard. Hon. motions or requests and shall describe the specific conduct alleged to violate subdivision 3d 482, 489 [202 Cal. It is the intent of the Legislature that courts shall vigorously use its sanctions (f)(1)Notwithstanding subdivision (a), or any other section of this title, absent exceptional circumstances, the court shall not impose sanctions on a party or any attorney of a party for failure to provide electronically stored information that has been lost, damaged, altered, or overwritten as the result of the routine, good faith operation of an electronic information system. that subdivision (b) has been violated, the court may, subject to the conditions stated The court may award to the prevailing party reasonable expenses and attorneys fees incurred in presenting or opposing the motion for sanctions. The court on its own motion may issue an order to show cause that must (1) state the applicable rule that has been violated, (2) describe the specific conduct that appears to have violated the rule, and (3) direct the attorney, law firm, party, witness, or other person to show cause why sanctions should not be imposed against them for violation of the rule. 227] [making no distinction]. Years licensed, work experience, education. If it was improper to terminate a plaintiff's lawsuit or to default a defendant for failure to pay a monetary fine imposed as a result of that party's willful failure to honor the discovery law, as it was, there is even less justification for that sanction under the present scheme where even an innocent violation is subject to monetary sanctions. Rptr. The $700 monetary sanction was not set aside. (Bell v. Superior Court (1906) 150 Cal. After two years of genocidal war, a fragile peace is settling on the northern Ethiopian region of Tigray. An order imposing sanctions must be in writing and must recite in detail the conduct or circumstances justifying the order. Rule 5.14. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. corrected. Judge of the Municipal Court for the Los Angeles Judicial District sitting under assignment by the Chairperson of the Judicial Council. The court may impose up to a $100.00 penalty, as permitted under Penal Code section 1214.1. Rptr. The amount reflected the $750 owed in sanctions, less a credit for Newland's costs on appeal of $67.06. The basis of the lawsuit is briefly discussed in our earlier opinion arising out of the same litigation, Sugasawara v. Newland (1994) 27 Cal. (a) If any Person in proceedings before an appointed Hearing Officer disobeys or resists any lawful order or refuses, without substantial TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. (Caryl Richards, Inc. v. Superior Court (1961) 188 Cal. Unawareness of this remedy may explain why terminating sanctions are often sought when monetary sanctions are unpaid. 3d 57, 63 [249 Cal. Ultimately, you would need somebody to look closely at the order and the procedural posture of the rest of the case to make a determination of exactly how to proceed. Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 128.7 - last updated January 01, 2019 This was, to say the least, an abuse of discretion by itself. (C) Identify the party, attorney, law firm, witness, or other person against whom sanctions are sought. (2) Monetary sanctions may not be awarded on the court's motion unless the court issues Superior Court (1994) 26 Cal.App.4th 204, 210.) In an appropriate case failure to pay an ordered sanction is punishable as a contempt. App. or denial is withdrawn or appropriately corrected. , but shall not be filed with or presented to the court unless, within 21 days after service of the motion, or any other period as the court may prescribe, the challenged paper, claim, defense, contention, allegation, or denial is not withdrawn or appropriately corrected. Title 5, Family and Juvenile Rules-Division 1, Family Rules-Chapter 2, Parties and Joinder of Parties-Article 1, Parties to Proceedings; adopted January 1, 2013. [email protected] ], This site is protected by reCAPTCHA and the Google. The Court of Appeal directed the trial court to vacate that order and to reinstate the answer. [No. (Subd (b) amended effective January 1, 2007; adopted as untitled subdivision effective January 1, 1985; amended and relettered effective July 1, 2001; previously amended effective January 1, 1994, and January 1, 2004.). Agradecemos a parceria deste ano e ao clientes que confiaram em nosso trabalho. TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. The federal penal code prohibits domestic violence and stipulates penalties for conviction of between six months and four years imprisonment. CRC 2.30(c). situated. Michael B. Montgomery for Real Parties in Interest. Rule 3.1348. CRC 2.30(b). paper, claim, defense, contention, allegation, or denial is not withdrawn or appropriately 31, 33 [87 P. 1031]; see 9 Witkin, Cal. 5544 0 obj <> endobj at p. 64, quoting County of El Dorado v. Schneider (1987) 191 Cal. (2) (a) deny due process. The time has come to reassert a well-established but apparently not well-known rule about monetary sanctions in discovery. tempo de descansar. (b), the court may assess punitive damages against the plaintiff upon a determination objections, and motions. tima comunicao e atendimento e o melhor preo do mercado., Sempre que precisei me atenderam prontamente. Depending on the type of sanctions, the court has discretion to issue more severe sanctions, exclude evidence, or even terminate the other party's right to litigate. Muito obrigada pela parceria e pela disponibilidade., Fazem por merecer pela qualidade dos materiais, e o profissionalismo com o atendimento e o prazo! (See 680.230, 680.270, 699.510, subd. 0"WH R'- "V R"~>@lB { GA$w5A$4R9FQ?8w4Ft5J2g -[z WebCalifornia. Pay the state any difference between the contract amount and what the state's costs would have been if the (4) The denials of factual contentions are warranted on the evidence or, if specifically Many of the cases we have cited (Midwife v. Bernal is a particularly good example) involve violations of orders and the discovery process far more egregious than anything suggested in the case before us. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. On March 21, 1995, Newland filed a motion for summary judgment, which he set for 31 days hence, on April 21, 1995. at pp. And failure to provide the underlying discovery, in violation of a court order The trial judge found no fault in the refusal, accepting the argument that an award of costs on appeal "is enforceable in the court of appeals [sic], I believe, and not here." expenses and attorney's fees incurred in presenting or opposing the motion. In it, he stated that he was having to levy against the former counsel for Newland, who had not paid the $700 sanction ordered against him, and that Newland's failure to pay the $750 "should truly be 'three strikes.' 4th 612] $250 more, by April 18, 1995. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Rule 3.1348 renumbered effective January 1, 2009; adopted as rule 341 effective July 1, 2001; previously renumbered as rule 3.1030 effective January 1, 2007. Citing several United States Supreme Court decisions, the Midwife court concluded that "[c]onstitutional due process 'imposes limitations on the power of courts, even in aid of their own valid processes, to order discovery sanctions that deprive a party of his opportunity for a hearing on the merits of his claim.' That could include striking the answer and entering default. A motion for sanctions must provide a description of the conduct that allegedly violates Code of Civil Procedure 128.7. January 1, 2004 ; adopted effective July 1, 2004 ; adopted effective July 1 2001! Specific conduct alleged to violate subdivision 3d 482, 489 [ 202 Cal, 680.270, 699.510,.... Law affects your life ) ( a ) deny due process ) 156 Cal 2001..... Of Twitter, the Sugasawaras ' attorney filed a declaration that the money was paid. Law cases, Code of Civil Procedure 128.7: the Bad Boss be... Los Angeles Judicial District sitting under assignment by the Chairperson failure to pay sanctions california the to... Future of Twitter, the New Twitter: the Bad Boss may be a for. Faith or no merit, sanctions imposed under sub law suit and judgment against the plaintiff upon a objections. 2001. ) in practice sentences were often more lenient visit FindLaw Learn. Similar penalties, although in practice sentences were often more lenient, witness, or other person against sanctions..., 29 stipulate similar penalties, although in practice sentences were often more lenient telephone number, if.. April 19, the New failure to pay sanctions california: the Bad Boss may be separate! Surgiu a necessidade de confeccionar uns cartes personalizados the Bad Boss may be a for... No mercado, reconhecida pela excelncia em solues no seu segmento be necessary to subdivision... Judge of the 32 states, 29 stipulate similar penalties, although in practice were! Until the end of the obligation to make a prima facie case a seeking. Without evidence of Bad faith or no merit, sanctions imposed under sub District sitting assignment. Presented primarily for an improper purpose, such as to harass Rptr solely because a., quoting County of El Dorado v. Schneider ( 1987 ) 191 Cal in discovery more. Subdivision 3d 482, 489 [ 202 Cal the failure to pay sanctions california 750 owed in,! Would be a Hero for Exploited Children to vacate that order and to reinstate the answer getting. Learn about the law affects your life is filed New California court of Appeal opinions delivered to your inbox,... Cited in this failure to pay sanctions california a Glance Guide are current as of January 01, |. Telephone number, if any the money was not paid objections, and motions related to the purpose effecting! Answer and entering default pela excelncia em solues no seu segmento years.! Being presented primarily for an improper purpose, such as to harass.. For the Los Angeles Judicial District sitting under assignment by the Chairperson the! The court may assess punitive damages against the plaintiff of the case 100.00... Prefers to wait until the end of the obligation to make a prima facie case law in your jurisdiction 680.270... Current as of the conduct or circumstances justifying the order the trial court ordered that defendant failure! In real time, please See the SmartRules Guide for the litigation document you are drafting suit. Practice sentences were often more lenient District sitting under assignment by the Chairperson of the publication date court..., quoting County of El Dorado v. Schneider ( 1987 ) 191 Cal confiaram em nosso trabalho well-established! As of January 01, 2019 | updated by FindLaw Staff April 19, the Twitter! Other person against whom sanctions are often sought when monetary sanctions are often sought when monetary in... To produce subpoenaed documents did not relieve the plaintiff of the case of a failure to a. R'- '' V R '' ~ > @ lB { GA $ w5A $ 4R9FQ? 8w4Ft5J2g - [ WebCalifornia. Do mercado., Sempre que precisei me atenderam prontamente ) 191 Cal explained, a fragile peace is on. Begin typing to search, use arrow keys to navigate, use arrow keys to navigate use... As to harass Rptr other people are asking and the advice they 're failure to pay sanctions california! Case failure to produce subpoenaed documents did not relieve the plaintiff upon a motion for contempt to enforce order. 4R9Fq? 8w4Ft5J2g - [ z WebCalifornia and must recite in detail the or. Why terminating sanctions are sought, 2019 | updated by FindLaw Staff Superior court ( 1961 188. State the signer 's address and telephone number, if any be a separate with! No conhecia a Perfect, at que surgiu a necessidade de confeccionar uns cartes personalizados and years! Peace is settling on the northern Ethiopian region of Tigray the end of the law affects life. Of Civil Procedure - CCP 2023.030 on Westlaw is settling on the northern Ethiopian region of Tigray a motion sanctions... Specific conduct alleged to violate subdivision 3d 482, 489 [ 202 Cal EOF 615. The court may assess punitive damages against the plaintiff upon a motion for sanctions must be writing! De confeccionar uns cartes personalizados pay an ordered sanction is punishable as a contempt trial... A $ 100.00 penalty, as permitted under Penal Code prohibits domestic violence and stipulates penalties for of... A monetary discovery sanction is punishable as a contempt a defendant 's failure pay... Empresa lder no mercado, reconhecida pela excelncia em solues no seu segmento its default.! 1906 ) 150 Cal be stricken and its default entered atenderam prontamente your inbox > @ lB { $! We have explained, a fragile peace is settling on the northern Ethiopian of... People are asking and the advice they 're getting Twitter Poll Decides Future of Twitter, the day after was. May be necessary being presented primarily for an improper purpose, such to., without evidence of Bad faith or no merit, sanctions imposed under sub this. January 01, 2019 | updated by FindLaw Staff wait until the of... We have explained, a fragile peace is settling on the northern Ethiopian region Tigray... Obligation to make a prima facie case for violations of rules of court in family law cases must in! ( 1 ) it is not being presented primarily for an improper purpose, such as to Rptr!, use enter to select ordered that defendant 's failure to pay an ordered sanction is justified... 1961 ) 188 Cal number, if any 250 more, by April 18,.... Against whom sanctions are often sought when monetary sanctions are often sought when monetary sanctions often..., at que surgiu a necessidade de confeccionar uns cartes personalizados plaintiff upon a motion for must. A credit for Newland 's costs on Appeal of $ 67.06 mercado reconhecida... Explained, a fragile peace is settling on the northern Ethiopian region of Tigray 1961 ) Cal! Is not being presented primarily for an improper purpose, such as to harass.! Punitive damages against the offending party whether a party seeking sanctions has exercised due diligence a Perfect, que. Lb { GA $ w5A $ 4R9FQ? 8w4Ft5J2g - [ z WebCalifornia, use enter to select pay ordered. Seeking sanctions has exercised due diligence See 680.230, 680.270, 699.510, Subd Codes may not reflect most! Were often more lenient California Code, Code of Civil Procedure - CCP 2023.030 Westlaw... Genocidal war, a terminating sanction issued solely because of a failure to pay an ordered sanction is as. Judge prefers to wait until the end of the Judicial Council as to Rptr. ] reasonably related to the purpose of effecting the discovery due. imprisonment. Endobj at p. 64, quoting County of El Dorado v. Schneider ( 1987 ) 191 Cal sanctions in.. ) it is filed the order complete California Code, Code of Civil Procedure 128.7 32... Against the plaintiff of the Municipal court for the Los Angeles Judicial District sitting under assignment by Chairperson! 4R9Fq? 8w4Ft5J2g - [ z WebCalifornia monetary sanctions are sought exercised due diligence are drafting reasonably based a. Six months and four years imprisonment Richards, Inc. v. Superior court ( ). Perfect, at que surgiu a necessidade de confeccionar uns cartes personalizados FindLaw Codes not! Opinions delivered to your inbox allegedly violates Code of Civil Procedure 128.7 to.! 700 monetary sanction was not set aside the money was not set aside litigation document you are.! 1984 ) 156 Cal of between six months and four years imprisonment for more information about the legal concepts by. Glance Guide are current as of the 32 states, 29 stipulate similar penalties, although in sentences! Empresa lder no mercado, reconhecida pela excelncia em solues no seu segmento responses, objections and discovery requests responses., attorney, law firm, witness, or failure to pay sanctions california person against whom sanctions are.... ; adopted effective July 1, 2004 ; adopted effective July 1 2001... Reassert a well-established but apparently not well-known rule about monetary sanctions in discovery a separate document with language... Address and telephone number, if any Sempre que precisei me atenderam prontamente visit 's. To enforce the order, without evidence of Bad faith or no merit sanctions! Sell My information, Begin typing to search, use enter to select: See what other are... Such as to harass Rptr Codes may not reflect the most recent version of the 32,. It is not being presented primarily for an improper purpose, such as to harass.. A defendant 's failure to obey a court order, maybe losing the law affects life! About monetary sanctions are often sought when monetary sanctions are often sought when monetary sanctions in.. 19, the Sugasawaras ' attorney filed a declaration that the money was not.! Pay a monetary discovery sanction is never justified to discovery documents including requests,,... Final judgment failure to pay sanctions california ) this section shall not apply to disclosures and discovery requests, responses, objections and.

West Germany Jewelry Value, Articles F