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Every discovery motion in California rises or falls on a document many attorneys treat as an afterthought: the meet and confer declaration. Code of Civil Procedure section 2016.040 requires a declaration stating “facts showing a reasonable and good faith attempt” to informally resolve “each issue presented by the motion.” Judges read these declarations with a practiced eye, and they can immediately tell the difference between a genuine effort and a box-checking exercise. A well-documented effort
July 20, 2026
July 20, 2026
Every discovery motion in California rises or falls on a document many attorneys treat as an afterthought: the meet and confer declaration. Code of Civil Procedure section 2016.040 requires a declaration stating “facts showing a reasonable and good faith attempt” to informally resolve “each issue presented by the motion.” Judges read these declarations with a practiced eye, and they can immediately tell the difference between a genuine effort and a box-checking exercise. A well-documented effort
Every discovery motion in California rises or falls on a document many attorneys treat as an afterthought: the meet and confer declaration. Code of Civil Procedure section 2016.040 requires a declaration stating “facts showing a reasonable and good faith attempt” to informally resolve “each issue presented by the motion.” Judges read these declarations with a practiced eye, and they can immediately tell the difference between a genuine effort and a box-checking exercise. A well-documented effort
May 26, 2026
Family law cases should settle. Yup, we said it.  Family law cases are meant to settle. That proposition may sound aspirational—especially in high-conflict custody disputes—but it remains both the goal and, in most cases, the most appropriate outcome.
Family law cases should settle. Yup, we said it.  Family law cases are meant to settle. That proposition may sound aspirational—especially in high-conflict custody disputes—but it remains both the goal and, in most cases, the most appropriate outcome.