A. Subject to the right of the responding party to seek a protective order, a party who attaches a declaration supporting additional discovery may propound a greater number if that greater number is warranted because of any of the factors set forth in Code of Civil Procedure sections 2030.040, subdivision (a) or 2033.040, subdivision (a). The court, for good cause shown, may make any order that justice requires to protect any party or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. | https://codes.findlaw.com/ca/code-of-civil-procedure/ccp-sect-2025-420/. You need to know what is out there to defuse and counteract the impact it may have on your clients case. (c) The party, deponent, or any other affected natural person or organization that taking into account the amount in controversy, the resources of the parties, the importance from U.C.L.A. CASE NO. (Glenfed Development Corp. v. Superior Court (1997) 53 Cal.App.4th 1113.). The Printed: 2/25/2021 02/25/2021 Motion: Protective Order r ZOlsrerV7283061 Page 1 0f 5 SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA MINUTE ORDER deposition notice shall state all 0f the following, in at least 12-point type: . What is most important is that you diligently pursue these records so your experts have the information they need. In the proposed order, ShipMate seeks to preclude Plaintiff from asking about items 1(e) and 7 (a) and (c) in Plaintiff's 30(b)(6) deposition notice. Current through the 2022 Legislative Session. Corp., 117 F.R.D. PDF. We have often recognized the inherent powers of the court to insure the orderly administration of justice.(Walker v. Superior Court(1991) 53 Cal. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. These depositions can have serious consequences because the witness's testimony is binding on the company. information. The cookie is used to store the user consent for the cookies in the category "Performance". Depositions: CCP 2025.420(b); Interrogatories: CCP 2030.090(b); Requests for Production: CCP 2031.060(b); Requests For Admission: CCP 2033.080(b). Under the Code of Civil Procedure in California, Section 2025.420 states that a party may move for a protective order before, during, or after deposition. Seek a protective order. This sample motion for a protective order for a deposition in California is filed under the provisions of Code of Civil Procedure 2025.420 (b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. 587, 593); and (2) defendants policies require a report regardless of whether plaintiff brought a lawsuit (See United States v. ChevronTexaco Corp. (N.D. Cal. sampling of electronically stored information on the basis that the information is Stay up-to-date with how the law affects your life. Cite this article: FindLaw.com - California Code, Code of Civil Procedure - CCP 2025.470 - last updated January 01, 2019 the sanction unjust. " [A] civil litigant's right to discovery is broad." (Williams v. Co. v. Superior Ct. (1992) 10 Cal.App.4th 1282, 1289. Incident reports and witness statements are not privileged. This sample motion for a protective order for a deposition in California is filed pursuant to Code of Civil Procedure 2025.420 (b) on the grounds that the moving party will suffer unwarranted annoyance, embarrassment, or oppression, or undue burden and expense if the court does not grant the motion for a protective order. (4) The likely burden or expense of the proposed discovery outweighs the likely benefit, Jurors typically do not like the extent that the investigators go to in order to conduct the sub rosa, so it is important to aggressively pursue this information and perhaps use it against them. and counsel, be excluded from attending the deposition. This can be done by refreshing your knowledge of the rules for properly noticing a deposition under the California Code of Civil Procedure (CCP) Sections 2025.210 et seq. is sought establishes that the information is from a source that is not reasonably Protective Order. You can also discuss using an independent discovery referee to help resolve the discovery dispute; however, discovery referees are very expensive. You must stay acutely aware of the defenses predictable discovery games and their abusive discovery tactics. However, plaintiffs counsel should argue that if the defense plans to use any of the sub rosa material at trial, they must produce all of the unedited footage, with sound if available, in its native format. (Suezaki v. Sup.Ct. Related posts. Attach your repeated meet and confer efforts as exhibits and include in your declaration the time and costs incurred in having to obtain the information, to prepare the motion documents, and to attend the hearing. What if you cant get a hearing date for the motion before your trial date? Her practice focuses on catastrophic personal injury, wrongful death, slip and fall and motor-carrier liability cases. FACTUAL BACKGROUND 2d 355, 385.) Section 2025.420 - Motion for protective order (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. (e) If the court finds good cause for the production of electronically stored information In response, Californias Judicial Council enacted Emergency Rule 11, which allowed deposition officers to be in a different location than deponents throughout the pandemic and for 90 days after the Governor declared that the state of emergency related to the pandemic was lifted. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. Cox Communications Kansas, LLC, the plaintiff in a Title VII retaliation suit against her former employer sought a protective order preventing her deposition from proceeding in person. Entering into a protective order permits game playing by the defense and encourages them to continue. h. "Information" means the content of Documents or Testimony. (3) the purpose of the statement or incident report. Chadboune, the dominant purpose of the report or statement determines whether the communication will secure privileged status. In sum, while there is no one-size-fits-all approach to whether depositions should proceed in person or remotely, courts are increasingly receptive to ordering deponents to appear in personwith appropriate precautions in place, such as masking, disclosure of vaccination status, and social distancing. Order for Material Witness Deposition Order For Psych Exam, Entry and Granting Motion. Under Rule 1.360 FRCP, in an action in which the mental or physical condition of a party is in controversy, examination of the party with respect thereto may be ordered, when good cause is shown therefor, without regard to the form or type of the civil action in which it is involved. Similarly, statements given or recorded by independent witnesses (and not at the specific request of the attorney) recounting the event at issue is not a confidential communication under the attorney-client privilege. When meet and confer efforts fail, plaintiffs counsel will bring a motion to compel the depositions. Proc., 2025.470.) If you are 12 or older and someone has asked for a restraining order against you, you can go to court without a parent. Item 7 does not seek information relating to the California action and therefore ShipMate's request for protective order as to Item 7 is now moot. This cookie is set by GDPR Cookie Consent plugin. The court may impose a monetary sanction ordering that one engaging in the misuse of the discovery process, or any attorney advising that conduct, or both pay the reasonable expenses, including attorneys fees, incurred by anyone as a result of that conduct. Chadbourne v. Superior Court (1964) 60 Cal.2d 723, 737.) One of the powers which has always been recognized as inherent in courts, which are protected in their existence, their powers and jurisdiction by constitutional provisions, has been the right to control its order of business and to so conduct the same that the rights of all suitors before them might be safeguarded.(Rice v. Superior Court (1982) 136 Cal.App.3d 81, 90(internal citations omitted).) CHAPTER 9 - Oral Deposition Inside California ARTICLE 4 - Objections, Sanctions, Protective Orders, Motions to Compel, and Suspension of Depositions Section 2025.420. For example, after the deposition where the store manager has admitted that they had to fill out incident reports after each incident in order to report safety concerns, or for training, or to avoid future incidents, defense counsel will often produce the incident report to avoid the threat of sanctions. Cal. (Code Civ. Depositions: CCP 2025.420 (b); Interrogatories: CCP 2030.090 (b); Requests for Production: CCP 2031.060 (b); and Requests For Admission: CCP 2033.080 (b). For example, defense attorneys have been known to propound hundreds of special interrogatories in a simple car-crash case. Regarding depositions, interrogatories, requests for production and requests for admission, a party bringing a motion for protective order must do so promptly after the need for the protective order arises. Pre-litigation investigations are not protected unless they are conducted by attorneys or under the direction of attorneys. The more you know about the sub rosa, the more effective you can defuse, downplay, or explain it, or even flip the evidence against the defense. Laura F. Sedrish is a Partner at Jacoby & Meyers in Los Angeles, CA. In his motion, Plaintiff argued that the COVID-19 pandemic is "good cause" under Code of Civil Procedure 2025.420 for the Court to issue a protective order against Defendants taking his deposition in person, citing Governor Newsom's ban on gathering with members from other households. If you are under 18, you can go to your local court's Self-Help Center for help. The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". respectfully moves this Court for a protective order prohibiting the depositions of Jim Reed and Sharon Smith, employees of the Supervisor of Elections of Hillsborough County. If defense notices an in-person deposition and you do not feel comfortable appearing, you can seek a protective order to have the deposition occur remotely. You are trying to discover, (2) who was present when the statement or incident report was given, and. Before, during or after a. A California Court of Appeals decision provides that a consumer may move to quash or modify a subpoena and does not limit that right to party consumers. A deposition must not be used against a party who, having received less than 14 days' notice of the deposition, promptly moved for a protective order under Rule 26 (c) (1) (B) requesting that it not be taken or be taken at a different time or placeand this motion was still pending when the deposition was taken. Argue that the defendants excessive discovery causes unwarranted annoyance, embarrassment, oppression, and undue burden and expense, and as such is an abuse of the discovery process. Twitter Poll Decides Future of Twitter, The New Twitter: The Bad Boss May Be A Hero for Exploited Children. You also have the option to opt-out of these cookies. Moreover, discovery is meant to take the game element out of litigation, not to inject it into the process. 9. The court may also impose this sanction on one unsuccessfully asserting that another has engaged in the misuse of the discovery process, or on any attorney who advised that assertion, or on both. In your meet and confer letter, discuss the objections offered, state that they are inapplicable, and state the basis of a further response. expense of discovery. STIPULATED PROTECTIVE ORDER . When defense plays games regarding insurance coverage, plaintiffs counsel should meet and confer early, in writing. Simply understanding that a crash caused steel to bend helps jurors visualize the level of impact felt by the plaintiff. (Crawford) (1962) 58 Cal.2d 166, 171.) Corporations, 50% Enjoy access to millions of ebooks, audiobooks, magazines, and more from Scribd. The CDA allows courts to issue protective orders that bar or limit the discovery of certain evidence, upon the motion of a party called to produce that evidence. In the interest of ensuring an efficient and prompt resolution of this action and of protecting confidential information from improper disclosure, the undersigned hereby stipulate, subject to approval and entry by the Court, to the following Protective Order issued . Any employee whose employment records are sought by a subpoena duces tecum may bring a motion to quash. The judge will likely grant them, since courts have a large backlog and judges do not want to spend time resolving routine discovery disputes. For patent cases, Patent Local Rule 2-2 provides that the "Protective Order authorized by the Northern District of California shall govern discovery unless the Court enters a different protective order.". (10) That the scope of the examination be limited to certain matters. the court in the district where the deposition is to be taken may make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or . ), California law is clear that the discovery act, while broad, does not support fishing expeditions that place more burden on the adversary than the value of the information warrants. (Greyhound Corp. v. Superior Court (1961) 56 Cal. Defense counsel often argue that the sub rosa is qualified work-product prepared at an attorneys direction and reflects counsels impressions, conclusions or theories, and is therefore entitled to protection per Code of Civil Procedure section 2018.030 and Suezaki v. Sup.Ct. Section 2025.420 - Motion for protective order (a) Before, during, or after a deposition, any party, any deponent, or any other affected natural person or organization may promptly move for a protective order. (See Code Civ. The cookie is used to store the user consent for the cookies in the category "Analytics". FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. In this era of pandemic and stay-home orders, we are seeing an uptick in billing opportunities by the defense, many involving issues dealing with discovery and non-compliance with the discovery statutes. Universal Citation: CA Civ Pro Code 2025.420 through (2015) Leg Sess 2025.420. 2020, ch. Order For Psych Exam Under 18 USC 4241.docx. California law is clear that failure to identify a witness in response to a valid discovery request can result in unfair surprise and is proper grounds for exclusion of that witness at trial. Proc., 97.) Under the California Code of Civil Procedure (CCP) 2025.420 (a) any "party, deponent, or any other affected natural person or organization" may move for a protective order "before, during or after" a deposition. To obtain information to which we are entitled, and to protect our clients from abusive discovery tactics, we must proactively file motions to compel and protective orders. These cookies ensure basic functionalities and security features of the website, anonymously. Under California Code of Civil Procedure 2025.420, the court, for good cause shown, may make any order that justice requires to protect any party, deponent, or other natural person or organization from unwarranted annoyance, embarrassment, or oppression, or undue burden and expense. Welcome to FindLaw's Cases & Codes, a free source of state and federal court opinions, state laws, and the United States Code. Californias Form Interrogatories- General (DISC-001) are designed to help attorneys ascertain basic information from defendants, including insurance coverage information, with minimal controversy or work involved. P., protective order unless the party seeking the deposition can show both the propriety and need for the deposition.'" Id. "The other and better approach considers that 'the mere request to depose a party's attorney constitutes good cause for obtaining a Rule 26(c), Fed. Order For Psych Exam Under 18 USC 4241 and 4242.docx . The plaintiff must show there is good cause for the court to bar or limit the discovery propounded. Be ready to file a motion to compel at the final status conference or in the days leading up to trial on an ex parte basis if new information is obtained further to the supplemental discovery responses. subdivision (f). The court shall limit discovery that is unreasonably cumulative, obtainable from a more convenient source, or unduly burdensome. Practice Pointer: If you have a corporate or entity defendant, in your deposition notice for the person most qualified, include subject areas and document requests regarding sub rosa and explore sub rosa at their deposition. A meet and confer letter is usually sufficient to get defense counsel to produce auto body repair records and photographs, but sometimes an IDC and/or motion is required. protective order for the Court's consideration. Current as of January 01, 2019 | Updated by FindLaw Staff. information, even from a source that is reasonably accessible, if the court determines File your motion, cite the new Code section, and ask for sanctions. is not reasonably accessible because of undue burden or expense. Greyhound Corp. v. Superior Court, (1961) 56 Cal.2d 355, 391 permits the parties to broad discovery. 111, 733 S.E.2d 412 (Ga.App. If the Designating Party timely seeks a protective order, the Party served with the subpoena 2002) 241 F.Supp.2d 1065, 1083 [finding that documents that would have been created in essentially similar form irrespective of the litigation are not entitled to work-product protection] (quoting United States v. Adlman (2d Cir. (Kiernan, David) (Filed on 12/9/2010) Download PDF Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. If a monetary sanction is authorized by any provision of this title, the court shall impose that sanction unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. directions: (1) That the deposition not be taken at all. If an order terminates the examination, the deposition shall not thereafter be resumed, In sum, in every case that sub rosa could be a game changer for the plaintiffs case, do not back down or drop the ball. Such designation shall be specific as to the portions of the transcript or any exhibit to be designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER. Current as of January 01, 2019 | Updated by FindLaw Staff. We also use third-party cookies that help us analyze and understand how you use this website. The conclusion is inescapable thatthe insurance policy is relevant to the subject matter] accord Irvington-Moore 14 Cal.App.4th at 739-40.). from the receipt of such written notice to apply to the Court for an order designating the material as confidential. These cookies will be stored in your browser only with your consent. Id . There are numerous articles on how to file motions to compel and general discovery motion practice tips and strategies. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. (h) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023.010) against any party, person, or attorney who unsuccessfully makes or opposes a motion In cases where the impact may not appear significant based on the photos, the auto body repair records can show frame damage and other relevant damage. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. Discovery in this action likely to involve production of confidential, is proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. (13) That a trade secret or other confidential research, development, or commercial Instead, plaintiffs should adamantly oppose any request for a protective order and not enter into one. Depositions: CCP 2025.420(a); Interrogatories: CCP 2030.090(a); Requests for Production: CCP 2031.060(a); and Requests For Admission: CCP 2033.080(a). At a minimum, the protective order could request the court order the deposition take place after the dispositive motion is heard, assuming the individual remains a named party. Seeking to stonewall the opposing party from discovery they would otherwise be entitled to is not a good option and would likely result in you losing your motion and being subject to sanctions. California CCP 2025 contains information regarding recording the testimony and objections, examination and cross-examination of the deponent. A-Z, Form (Long Decl 6, Ex. 112, 3) that (1) removed . Necessary cookies are absolutely essential for the website to function properly. The motion for protective order acts to effectively stay the Rule 30 (b) (6) deposition until the court resolves the motion. Current as of January 01, 2019 | Updated by FindLaw Staff ( )... The category `` Functional '' there is good cause for the Court to insure orderly... Analyze and understand how you use this website, plaintiffs counsel should meet and confer efforts,. To bend helps jurors visualize the level of impact felt by the defense and encourages them continue. Receipt of such written notice to apply to the Court for an order designating Material... The information is Stay up-to-date with how the law affects your life,! Chadbourne v. Superior Court ( 1991 ) 53 Cal.App.4th 1113. ) )! The Bad Boss may be a Hero for Exploited Children also discuss using an independent referee. # x27 ; s Self-Help Center for help Stay up-to-date with how the law affects your life defense attorneys been. Compel and general discovery motion practice tips and strategies consent for the cookies in category! Burden or expense obtainable from a source that is unreasonably cumulative, from! Self-Help Center for help administration of justice investigations are not protected unless they are conducted by attorneys under! Compel the depositions Performance '' injury, wrongful death, slip and fall and protective order deposition california liability cases testimony binding. Aware of the examination be limited to certain matters tecum may bring a motion to quash Court & x27., and more from Scribd for the Court to bar or limit the discovery dispute ; however discovery! Defenses predictable discovery games and their abusive discovery tactics is meant to take the game element of... Games regarding insurance coverage, plaintiffs counsel should meet and confer early, in writing features of the website function! Relevant to the subject matter ] accord Irvington-Moore 14 Cal.App.4th at 739-40. ). ). ) ). You use this website to continue felt by the defense and encourages them to continue level... Go to your local Court & # x27 ; s Self-Help Center for help cookies are absolutely for... Use this website the Material as confidential chadbourne v. Superior Court ( 1982 ) 136 Cal.App.3d 81, 90 internal! Propound hundreds of special interrogatories in a simple car-crash case 1997 ) Cal.App.4th... Your clients case element out of litigation, not to inject it into process! Wrongful death, slip and fall and motor-carrier liability cases is that you diligently pursue these records your! Protective order, or unduly burdensome ( Greyhound Corp. v. Superior Court, ( 1961 ) Cal.2d! There to defuse and counteract the impact it may have on your clients case by... 2025 contains information regarding recording the testimony and objections, examination and of. Felt by the defense and encourages them to continue Pro Code 2025.420 through ( 2015 ) Sess... More from Scribd: CA Civ Pro Code 2025.420 through ( 2015 ) Leg Sess 2025.420 or under the of! Whether the communication will secure privileged status to know what is most important is that you diligently pursue records. And general discovery motion practice tips and strategies sampling of electronically stored information on the company dominant purpose the! ) who was present when the statement or incident report was given, and impact felt by plaintiff! 1113. ). ). ). ). ). ). )..... General discovery motion practice tips and strategies motion to compel and general discovery practice... Is out there to defuse and counteract the impact it may have on your clients case cant a. ( 10 ) that ( 1 ) removed and counteract the impact it may have on your clients case regarding... To bend helps jurors visualize the level of impact felt by the must! Insurance policy is relevant to the Court & # x27 ; s consideration from Scribd 3 ) purpose! Statement determines whether the communication will secure privileged status confer efforts fail, plaintiffs will. Directions: ( 1 ) removed simple car-crash case of such written notice to apply to the subject ]... Burden or expense, or unduly burdensome examination be limited to certain matters 1962 ) 58 Cal.2d 166 171... Reflect the most recent version of the website, anonymously that you diligently pursue these records so your have! The cookie is set by GDPR cookie consent plugin information they need get! You diligently pursue these records so your experts have the option to opt-out of these cookies be... The user consent for the Court for an order designating the Material as.... Propound hundreds of special interrogatories in a simple car-crash case good cause for the website, anonymously confidential! From the receipt of such written notice to apply to the Court shall limit that... ) the purpose of the law in your jurisdiction ( internal citations omitted ) ). Be a Hero for Exploited Children personal injury, wrongful death, slip and fall and motor-carrier liability cases Glenfed... To opt-out of these cookies consent for the motion before your trial date your experts have the is! ; means the content of Documents or testimony insurance policy is relevant to the subject ]... May be a Hero for Exploited Children discuss using an independent discovery referee to help resolve discovery... Decides Future of Twitter, the dominant purpose of the deponent at all 1113. ) )! On how to file motions to compel and general discovery motion practice tips and.! Decl 6, Ex, wrongful death, slip and fall and motor-carrier liability cases F.... Example, defense attorneys have been known to propound hundreds of special interrogatories in a simple car-crash.... Attorneys have been known to propound hundreds of special interrogatories in a simple car-crash case secure privileged.... Acutely aware of the defenses predictable discovery games and their abusive discovery.. Counsel should meet and confer efforts fail, plaintiffs counsel will bring motion... Greyhound Corp. v. Superior Court ( 1991 ) 53 Cal Performance '' the! To the Court to insure the orderly administration of justice understand how you this... And more from Scribd hearing date for the cookies in the category `` ''! Learn about the law, 2019 | Updated by FindLaw Staff discovery tactics law your! Court, ( 2 ) who was present when the statement or incident report or determines! Is binding on the company Partner at Jacoby & Meyers in Los,. Statutes, visit FindLaw 's Learn about the law in your jurisdiction matter ] protective order deposition california... Basis that the information is Stay up-to-date with how the law in your jurisdiction consequences because witness! 81, 90 ( internal citations omitted ). ). ). )... From Scribd is out there to defuse and counteract the impact it may have on your clients case of burden! Counsel will bring a motion to compel and general discovery motion practice tips and strategies when meet confer... Source that is unreasonably cumulative, obtainable from a source that is cumulative. Leg Sess 2025.420 practice tips and strategies motions to compel the depositions ( 1964 ) 60 Cal.2d 723,.. From Scribd Court to bar or limit the discovery dispute ; however, discovery is meant protective order deposition california take the element. The orderly administration of justice bar or limit the discovery dispute ; however, discovery is meant to take game... Be taken at all: CA Civ Pro Code 2025.420 through ( ). 50 % Enjoy access to millions of ebooks, audiobooks, magazines, and from. 739-40. ). ). ). ). ). )..... Features of the Court shall limit discovery that is not reasonably protective order permits game playing the. Coverage, plaintiffs counsel will bring a motion to compel and general discovery motion practice and... Articles on how to file motions to compel the depositions 2019 | Updated FindLaw. By the plaintiff Angeles, CA statement or incident report was given and... Must show there is good cause for the website, anonymously store the user consent for the shall! From a source that is not reasonably protective order 90 ( internal citations omitted ). )..... Discovery referees are very expensive the subject matter ] accord Irvington-Moore 14 Cal.App.4th at 739-40. ). ) )! ( 2015 ) Leg Sess 2025.420 this website ] accord Irvington-Moore 14 at. ) ( 1962 ) 58 Cal.2d 166, 171. )... Consent for the Court to bar or limit the discovery dispute ; however, discovery is meant to take game... The scope of the Court to insure the orderly administration of justice the Bad Boss may be Hero... H. & quot ; means the content of Documents or testimony or limit the discovery propounded Enjoy to! Defense plays games regarding insurance coverage, plaintiffs counsel should meet and confer fail. Twitter Poll Decides Future of Twitter, the dominant purpose of the law in your.... Confer early, in writing Sedrish is a Partner at Jacoby & Meyers in Los Angeles CA! ; however, discovery referees are very expensive referee to help resolve the discovery dispute ; however, discovery meant!, 3 ) that ( 1 ) that the information they need h. & quot ; information & ;... Testimony is binding on the basis that the information they need because of undue burden or expense been known propound... When the statement or incident report the witness & # x27 ; s testimony is binding on the.! You also have the option to opt-out of these cookies ensure basic functionalities and security features of the deponent or! Unreasonably cumulative, obtainable from a more convenient source, or unduly burdensome the cookie is used to store user... Cross-Examination of the Court & # x27 ; s testimony is binding on the basis the... ) the purpose of the examination be limited to certain matters, ( 1961 ) 56 Cal the..

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