Business Dispute — Meet & Confer Regarding Discovery Deficiencies
How a defense team turned evasive discovery responses into a motion-ready meet-and-confer record.
Outcome Snapshot
Full meet-and-confer workflow. 75 responses reviewed. Every deficiency cited.
A defense team facing evasive answers and boilerplate objections needed to put the responding party on notice before a motion to compel. Using Inquisita to cross-reference the case record, they analyzed every response against the governing Code of Civil Procedure standards, surfaced documents that contradicted claims of “no responsive documents,” and produced a meet-and-confer letter precise enough that each demand named the section it enforced.
How it was done — 4-step workflow
Gather responses and case context
The team collected the opposing party's responses across all four discovery types and pulled the matter record from Inquisita to test each answer against what the file actually showed.
75 responses · full record cross-referencedAnalyze each response by type
Every response was measured against its governing standard: completeness and good-faith effort for interrogatories, statements of compliance and inability for RFPs, and specific denials for RFAs. Each deficiency was then tied to the exact CCP provision it violated.
23 deficiencies — each cited to the CCPCross-reference the record
Where the responding party claimed no responsive documents or no knowledge, Inquisita searched the record for contradicting material. Six documents in the file undercut a “no documents” response and anchored the demand to supplement.
6 contradicting documents surfacedDraft the letter and memo
Inquisita first summarized the opposing party's produced responses, then drafted the meet-and-confer letter organized by request number, with each deficiency stating its cure and a firm deadline, plus an internal work-product memo logging the contradicting evidence and the calculated motion-to-compel deadline.
2 work products — letter · privileged memo