Please answer the following using California Code of Civil Procedure and other California statutes.

20. Once an expert is disclosed as an expert that will testify at trial: a. b. P- Franz-w The communications between the expert and the attorney remain the work product of the attorney. The communication between the expert and the attorney are not protected by the work product privilege and are not protected by the attorney client privilege. The documents reviewed by the expert still remain the work product of the attorney. The documents reviewed by the expert are discoverable and not protected by the work product privilege. All writings by the expert in connection with the case are discoverable. a. & c. b., d & e. None of the above. 21. Failure to follow the rules regarding expert witness designations, exchange for information, etc., may result in: a. d. b c e The expert being sanctioned by the court. The attorney being sanctioned by the court. The expert's testimony being excluded at trial. All of the above. None of the above. 22. If no responses to Requests for Admissions are received, the propounding party may: a. b. Move the court for an order deeming the requests admitted for all purposes of the litigation. Move the court for an order imposing sanctions against the responding party. c. Both a & b. (1. None of the above. 23. Failure to timely respond to Requests for Admissions: a. b. C. rm Waives all rights to object or claim privileges, including work product and attorney client privileges. Will automatically result in the Requests being deemed admitted. Allows the propounding party to move for an order deeming the requests admitted. a, b, 8: c. a & c. None of the above. 24. A written response to a Demand for an IME, must be served within of the service of the demand. a. 10 days b. 5 days c. 30 days (1. 20 days e None of the above. days 25. A demand for an IME must be served at least days prior to the date of the examination, unless a court issues an order shortening time. a. 10 days b. 5 days c. 30 days (1. 20 days e None of the above. PART II TRUE 0R FALSE Please write TRUE or FALSE (\"T" or \"P" will also sufce) as appropriate in each blank below: 26. Motions to Compel Further Discovery must contain a \"Separate Statement of the Discovery in Dispute\". 27 The difference between the attomeyi'client and attorneyfwork product privileges is that the attorney work product privilege belongs to the client. 28. The scope of discovery 15 broader than that which 1s admissible at trial and may include evidence that may be objectionable at trial such as hearsay and subsequent remedial measures as long as it is not privileged. 29. In unlimited civil cases, parties are limited to using 35 Requests for Admission unless: the requests pertain to the genuineness of documents, a Declaration for Additional Discovery is attached to those requests for admission, or the parties stipulate to additional requests for admission. 30. Plaintiff may serve discovery at any time 31. Defendant may serve discovery at any time 32. A party has 30 days plus 5 days mailing to respond to Form Interrogatories if they are served by US Mail and from a location within the State of California. 33. Discovery requests are led with the court. 34. Motions may be brought at any stage of a case. 35. An inspection demand is prepared on pleadings paper and is signed by the attorney serving the demand. 36. Motions do NOT require Declarations of the attorney in support of the Motion. 3?. Motions for Summary Judgmentx'Summary Adjudication must have a Separate Statement of Undisputed Facts. 38. In an UNLIMITED civil case, there is no limit on the number of inspection demands a party may make except that supplemental demands to inspect later- acquired or discovered documents are limited to 2 prior to the initial setting of the trial date and once aer each subsequent trial setting. 39. In responding to a demand for production of documents it is permissible to object and still respond and produce the documents requested without waiving the objection. 40. Ex parte applications do NOT require proposed orders. 41. A response to discovery that contains only objections MUST be veried by the client. 42. Motions to compel initial discovery responses may be made at any time after the response is due without the need to rst meet and confer with opposing counsel. 43. A privilege objection bars discovery and the burden is upon the discovering party to move to compel. 44. Responses to discovery may be used at trial but may only be admissible against the responding party. 45. Motions to compel further discovery responses must be made within 45 days after the responses were served. 46. Motions to compel further discovery responses can be made without the need to rst meet and confer with opposing counsel. 4?. Objections which are not timely served are not waived. 48. The scope of discovery is strictly construed. 49. Form Interrogatories contain permissible sub parts. .C-'mr'intr 7H7? Final \"Yam p209 I 7