California litigators, what methods have you come up with for easy compliance with CCP 2031.280(a)? It’s fine with a relatively contained document production and limited number of requests. But when there are thousands of responsive documents to dozens of overlapping RFPs, with some documents responsive to more than one request, it quickly turns into a huge pain in the ass.

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Senior Counsel 1 - Have you actually tried arguing that the new statute is silent as to what to do when a document is responsive to multiple requests? I feel like a reasonable interpretation would be to require you to state each request the document is responsive to, instead of interpreting it as not knowing what to do if your document is responsive to more than one request.

Make an index on a separate sheet, one column with the RFP numbers and the second with the responsive pages. I don’t think there’s a way to make it not be a pain. This is the best way I’ve figured out to do it so far....Interested in other ideas!!

Yeah, that’s the method I use for smaller productions. Curious to see if anyone has figured out a less labor-intensive method for larger productions.

Largely depends on how I requested docs from client.... if so, I’ll compile the docs pursuant to my first request to client as exhibit a and so on and so forth. If I have any doubt that exhibit C can be responsive to the disc request I’ll just refer to exhibit a and c .

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Seems accurate 😊

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