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In a state court case in California involving 5 defendants, 2 defendants (the CEO of a company and the company itself) have objected to producing all documents requested in the RFPD on several grounds, including lack of particularization, violation of attorney-client privilege, proprietary rights, trade secrets, and privacy rights. The complaint includes claims of unfair competition, defamation, and breach of fiduciary duty. Should a motion to compel further responses be filed, and if so, what are the steps to do so?

April 30th, 2024

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