Legal Question in Real Estate Law in California

The law favors simplifying the discovery process. Perhaps it should, because the law and current practice have rendered it time-consuming, cumbersome and expensive. At any rate, there are "meet and confer" and "written stipulation for modification of procedures" provisions built in to the discovery law here and there. I would suggest a discussion with opposing counsel as to short-cuts that can be agreed upon to save both parties time and expense, and reduce the thickness of both sets of files.

Perhaps needless to say, the other side will want to be assured that the documents satisfying one discovery demand are indeed identical to those which would be furnished in response to the other demand.

Furthermore, opposing counsel can and perhaps will want to see the documents in advance of the deposition, so he/she can prepare. Nevertheless, I think that reasonable parties and attorneys can simplify paperwork exchanges by talking to each other and negotiating. Then get it in a written stipulation.

Answering an inspection demand requires two steps. A response under oath that meets the statutory requirements, and production for inspection of the documents that you state you will allow to be inspected.

You do not mention whether the motion to compel is to compel responses to the inspection demand, to demand further responses in areas that were not appropriately responded to, or a motion to compel compliance with your stated agreement to produce.

Producing some documents at a deposition will not render the motion moot.