--- name: ca-discovery-verification title: California Discovery Verification description: Drafts California Superior Court discovery verification pages under CCP §§ 2030.250 and 2031.250 with proper CCP § 2015.5 perjury declarations. Trigger when the user needs a verification page for interrogatory or inspection/RPD responses, mentions California discovery verification, party vs. attorney signing, information-and-belief clauses, or fixing unverified responses. CA Superior Court only — not federal. author: CaseMark author_url: https://github.com/CaseMark/skills/tree/main/skills/legal/ca-discovery-verification license: Apache-2.0 version: 0.1.0 execution_mode: open jurisdiction: us practice: litigation language: en tags: [drafting] --- # California Discovery Verification Produces correctly formatted CA verification pages with proper signer capacity, knowledge basis, and CCP § 2015.5 perjury declaration. Unverified responses are treated as no response — the responding party waives objections and faces motions to compel (*Appleton v. Superior Court* (1988) 206 Cal.App.3d 632 [VERIFY]). ## Quick Start 1. Gather intake details (see Pre-Draft Intake) 2. Select verification type by discovery device 3. Select knowledge basis clause 4. Draft verification from template 5. Run quality audit 6. Confirm alignment with user ## Pre-Draft Intake Gather before drafting (apply labeled defaults if user says "use defaults" or "just draft"): | Field | Details | Default | |---|---|---| | Discovery device | Interrogatories (Form/Special) or inspection demand/RPD | Interrogatory | | Exact response title | Must match verbatim on verification | — | | Caption info | Court name, case number, party names | — | | Responding party type | Individual or entity (corp, LLC, partnership) | Individual | | Signer identity | Legal name, title/role, authority basis (entities) | — | | Knowledge basis | Personal knowledge only, or information and belief | Info & belief | | Execution details | Date, city, state | — | > Do not draft verification for responses that have not been finalized. ## Step 1: Select Verification Type | Device | Statute | |---|---| | Interrogatories (Form/Special) | CCP § 2030.250 | | Inspection demand / RPD | CCP § 2031.250 | | Federal court | Stop — use FRCP 33/34 + 28 U.S.C. § 1746 [VERIFY] | ## Step 2: Select Knowledge Basis - **Personal knowledge only**: "The matters stated in the foregoing responses are true of my own knowledge." - **Information and belief** (signer relied on records, employees, or collected info): "The matters stated in the foregoing responses are true of my own knowledge, except as to those matters stated on information and belief, and as to those matters I believe them to be true." ## Step 3: Draft Verification ### Individual Template ```text [CAPTION BLOCK] VERIFICATION OF [PARTY NAME] TO [EXACT RESPONSE TITLE] I am the [plaintiff/defendant] in this action. I have read the foregoing responses and know the contents thereof. [KNOWLEDGE BASIS CLAUSE] I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on [DATE], at [CITY], [STATE]. ___________________________ [SIGNER NAME] [Plaintiff/Defendant] ``` ### Entity Template ```text [CAPTION BLOCK] VERIFICATION OF [ENTITY NAME] TO [EXACT RESPONSE TITLE] I am the [TITLE] of [ENTITY NAME], a party to this action, and am authorized to make this verification for and on its behalf. I have read the foregoing responses and know the contents thereof. [KNOWLEDGE BASIS CLAUSE] [OPTIONAL: "I am informed by the employees and records of [ENTITY NAME] regarding the matters stated."] I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on [DATE], at [CITY], [STATE]. [ENTITY NAME] By: _______________________ [SIGNER NAME] Its: [TITLE] ``` Templates apply to both interrogatory and inspection/RPD verifications — select the matching type from Step 1. ## Post-Draft Alignment After delivering, confirm with the user: 1. Verification title matches response document title exactly 2. Signer has proper authority (especially for entities) 3. Knowledge basis clause is appropriate 4. Execution location is correct (out-of-state may need adjustment) ## Quality Audit Before finalizing, verify all of the following: - [ ] Verification title matches response title verbatim - [ ] Signer capacity stated; entity authorization language included - [ ] CCP § 2015.5 perjury language verbatim: "under the laws of the State of California" - [ ] Execution date and city/state present - [ ] Signature block includes name and capacity - [ ] Objections not verified (attorney signs for objections) - [ ] Knowledge basis clause matches actual basis of responses - [ ] Federal court not using CCP form - [ ] No attorney signature where party signature required ## Pitfalls - Title mismatch between verification and response invites motions to compel - Attorney-signed verifications invalid except narrow CCP § 446 circumstances [VERIFY] - "Personal knowledge" clause wrong if signer relied on records — use information-and-belief - Never verify legal objections — attorney signs the response document for those - Omitting "under the laws of the State of California" from perjury declaration is a fatal defect - No notarization unless court order or client policy requires it - Perjury exposure for false verifications (Cal. Penal Code § 118) [VERIFY] - All case citations must be verified or flagged `[VERIFY]` — do not invent case law - **Attorney review required** — all output must be reviewed by supervising counsel before signature or service