Karl D Pope vs. Peter Hauber

Case No.: 56-2009-00345482-CU-BC-VTA    

Plaintiff, Karl Pope, has moved to compel (further) responses to an inspection demand. Defendant opposes the motion. The heart of the motion is the claim of privilege to certain documents.

Any motion, including one to compel further responses to a demand for inspection of documents or tangible things, involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. (CRC, Rule 3.1345(a).) A separate statement must contain certain information. (CRC, Rule 3.1345(c).) A separate statement must provide "all the information necessary to understand each discovery request and all the responses to it that are at issue." (Ibid.) A separate statement is not sufficient if the reader "is required to review any other document in order to determine the full request and the full response." (Ibid.)

Plaintiff's separate statement is deficient in several respects. First, it attaches a series of four exhibits, an........