GUIDE TO LAW OFFICE PROCEDURES MANUAL

DISCOVERY CHAPTER

CHAPTER D

PROJECT #1

OBJECTIVE

Using the LOPM, Chapter D. pg. D-36.1 and pg 39 as a reference.  Students will prepare the Notice of Deposition and list the steps necessary for coordinating, noticing, and scheduling two depositions in the same case as follows:

Date Depositions May 15, 200x

a.	Notice of Deposition and Request for Production of Documents of a party to the action; and
b.	Proof of Service.
c.	Notice of Deposition of an individual who is not a party to the action but a witness.
d.	Prepare a Deposition Subpoena for non-party.
e.	Proof of Service.
f.	Research if the non-party needs a witness fee in the Rules of Court.
g.	Enclose an appropriate fee, if needed.
h.	Reserve the firm’s conference room for the deposition.
i.	Calendar the dates for the Depositions (in-class exercise).

LOPM Reference: Chapter D

Other Reference:  LSI Legal Professional’s Handbook

INSTRUCTIONS TO STUDENTS

You are the secretary to Charles Henry Grim of GRIM & BARRETT, Attorneys at Law, whose address is 28 North First Street, San Jose, California 95113; telephone number (408) 298-9519.  Mr. Grim’s California State Bar Number is 987678.  The office represents defendant B. S. Letum.  Today’s date is May 15, 200x.

Facts:
1.	Using the Law Office Procedures Manual as a reference, prepare Notices of Taking the Depositions of the following people:

A.	Plaintiff,  I. M. Herting, who is also to produce the following documents at the time of his deposition:

1.	Any and all medical bills;
2.	Documentation verifying alleged wage loss;
3.	Any and all documents which substantiate plaintiff’s automobile damage claims; and
4.	All photographs which in any way relate to the subject of this lawsuit.

B.	Witness, Ms. Ima Witness, whose residence address is 1525 Midway Drive, San Jose, California.

Schedule the depositions on two separate days. The depositions will be taken at Mr. Grim’s office at 10:00 a.m.

2.	Prepare a list of the steps you would take in scheduling these depositions.

PROJECT #2

OBJECTIVE

Using the LOPM, Chapter D, pgs. D-17 thru D-24 as a reference, the student will prepare the following documents:

Date Interrogatories March 30, 200x

a.	Form Interrogatories; and
b.	Proof of Service. 
c.	Research the Rules for the time required to Answer the Interrogatories
d.	Calendar the date for the Answer to Interrogatories from opposing counsel (in-class exercise).

LOPM Reference:  Chapter D

Other Reference:  LSI Legal Professional’s Handbook

INSTRUCTIONS TO STUDENT

Using the Law Office Procedures Manual as a guide, prepare a set of Form Interrogatories using the following information:

Facts:

You are employed by U. R. Aiken, Attorney at Law, whose address is 480 North First Street, San Jose, California 95112; telephone number (408) 377-1234. Mr. Aiken’s California State Bar Number is 12345g. You are preparing Form Interrogatories, Set No. One. The Asking Party is your clients, I. M. Herting and his daughter, Constance Herting. The Answering Party is defendant B. S. Letum.  Today’s date is March 30, 200x 

Form Interrogatories

The following are the questions to be propounded:

Interrogatories No.
	1.1
all questions in the 2 series
4.1
4.2
all questions in the 12 series
14 .1
15.1
all questions in the 16 series
all questions in the 20 series

PROJECT #3

OBJECTIVE

Using the LOPM, Chapter D pg. D-59 as a reference, the student will prepare the following document:

Date Demand for Identification, et al. April 10, 200x

a.	Demand for Identification, Production, and Inspection of Documents and Other Tangible Things;
b.	Proof of Service.
c.	Research the Rules for the time required for Response or Oppose the Demand for Production of Documents
d.	Calendar the date for Response to Demand from opposing counsel (in-class exercise).

LOPM Reference:  Chapter D

Other Reference:  LSI Legal Professional’s Handbook

INSTRUCTIONS TO STUDENT

Using the Law Office Procedures Manual as a guide, prepare a Demand for Identification, Production, and Inspection of Documents and Other Tangible Things using the following information.

Facts:

You are employed by U. R. Aiken, Attorney at Law, whose address is 480 North First Street, San Jose, California 95112; telephone number (408) 377-1234. Mr. Aiken’s California State Bar Number is 123456. You are preparing a Demand for Identification, Production, and Inspection of Documents and Other Tangible Things, Set No. One. The Demanding Party is your clients, I. M. Herting and his daughter, Constance Herting. The Responding Party is defendant B. S. Letum. Today’s date is April 10, 200x 

Demand for Production of Documents and Things:

The following are the items to be produced:

Any and all documents relating to the physical condition of the automobile you were operating at the time of the incident in the above captioned matter.

The actual production of documents should be set in conformance with the statutory limits.