calcivilguideCalifornia civil procedure Search ⌘K

California civil procedure, for practitioners

The rule, and what it costs to miss it

Every page opens with the answer and a pin cite, then says what breaks if you get it wrong, and whether it is fixable.

Hot topics

Not civil procedure, and not California, but it lands on a California practitioner's desk anyway. Why these are here.

Discovery, and the courts outside California

Your client’s ChatGPT history is discoverable

No lawyer was in the conversation, so Evidence Code 952 never reaches it. What the requests look like, the objections that hold, the section 912(a) waiver when a client pastes your advice into a chatbot, and the spoliation exposure when the client clears the history.

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Most competing pages on these topics are not wrong because they were written badly. They are wrong because nobody went back.

Why I write this

These are problems I actually run into. When I have to work out whether a supplemental response restarted a clock, whether a 998 offer survives a broad release, or what a notice declaration has to recite, I do the research anyway because a case depends on it.

Writing the answer down afterward costs almost nothing, and the answer does not change depending on who needs it. So I am sharing the work instead of letting it sit in a case file.

Every page here started as a question I had to answer for a real matter. That is also why each one says what happens when you get it wrong. That is the part I actually wanted to know.

Who writes it, and what it is not

I am not selling anything. I do not take clients through this site, there is no hire-me button, and I do not advertise my practice here. No ads, no ad network, nothing sold and nothing shared. Google Analytics counts which pages get read, which is how I know what to write next, and that is the only measurement on the site.

My name is on it. My firm is not, and will not be. A firm on these pages would turn a reference into a credential, and then it starts getting written to make someone look good. The paragraph above is what keeps that from happening, not the byline.

Jacob H. Katz, a licensed California attorney. I litigate civil cases in California state court, and I have taken and defended the discovery this site is about. I practice across California, and in federal court in California and Florida.

You should not trust any of this because of who wrote it. You should trust it because you can check it. More on that.

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Be told when a guide goes up or changes

One line per new guide, one per material revision, one per correction. Typo fixes do not go out, because a list you learn to ignore is worse than no list. Usually one or two a month, sometimes none. Your address is used for that and nothing else, it is never sold, shared or handed to anyone, and every message carries an unsubscribe link that works on the first click.

Prefer to hand over nothing? Use the feed instead. It carries the same items, in full, and there is no list for anyone to ask me for.

Or hand over nothing at all

A feed asks for no address, keeps no consent record, and leaves no list that anyone could ever ask me for. It carries the full text of every guide, so your reader becomes a usable archive on its own.

https://calcivilguide.com/feed.xml

What the feed carries, and how to set one up in two minutes.