California Code of Civil Procedure Section 2017

2017.  (a) Unless otherwise limited by order of the court in
accordance with this article, any party may obtain discovery
regarding any matter, not privileged, that is relevant to the subject
matter involved in the pending action or to the determination of any
motion made in that action, if the matter either is itself
admissible in evidence or appears reasonably calculated to lead to
the discovery of admissible evidence.  Discovery may relate to the
claim or defense of the party seeking discovery or of any other party
to the action.  Discovery may be obtained of the identity and
location of persons having knowledge of any discoverable matter, as
well as of the existence, description, nature, custody, condition,
and location of any document, tangible thing, or land or other
property.
   (b) A party may obtain discovery of the existence and contents of
any agreement under which any insurance carrier may be liable to
satisfy in whole or in part a judgment that may be entered in the
action or to indemnify or reimburse for payments made to satisfy the
judgment.  This discovery may include the identity of the carrier and
the nature and limits of the coverage.  A party may also obtain
discovery as to whether that insurance carrier is disputing the
agreement's coverage of the claim involved in the action, but not as
to the nature and substance of that dispute.  Information concerning
the insurance agreement is not by reason of disclosure admissible in
evidence at trial.
   (c) The court shall limit the scope of discovery if it determines
that the burden, expense, or intrusiveness of that discovery clearly
outweighs the likelihood that the information sought will lead to the
discovery of admissible evidence.  The court may make this
determination pursuant to a motion for protective order by a party or
other affected person.  This motion shall be accompanied by a
declaration stating facts showing a good faith attempt at an informal
resolution of each issue presented by the motion.
   The court shall impose a monetary sanction under Section 2023
against any party, person, or attorney who unsuccessfully makes or
opposes a motion for a protective order, 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.
   (d) In any civil action alleging conduct that constitutes sexual
harassment, sexual assault, or sexual battery, any party seeking
discovery concerning the plaintiff's sexual conduct with individuals
other than the alleged perpetrator is required to establish specific
facts showing good cause for that discovery, and that the matter
sought to be discovered is relevant to the subject matter of the
action and reasonably calculated to lead to the discovery of
admissible evidence.  This showing shall be made by noticed motion
and shall not be made or considered by the court at an ex parte
hearing.  This motion shall be accompanied by a declaration stating
facts showing a good faith attempt at an informal resolution of each
issue presented by the motion.
   The court shall impose a monetary sanction under Section 2023
against any party, person, or attorney who unsuccessfully makes or
opposes a motion for discovery, 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.
   (e) (1) Pursuant to noticed motion, a court may enter orders for
the use of technology in conducting discovery in cases designated as
complex pursuant to Section 19 of the Judicial Administration
Standards, cases ordered to be coordinated pursuant to Chapter 3
(commencing with Section 404) of Title 4 of Part 2, or exceptional
cases exempt from case disposition time goals pursuant to Article 5
(commencing with Section 68600) of Chapter 2 of Title 8 of the
Government Code, or cases assigned to Plan 3 pursuant to paragraph
(3) of subdivision (b) of Section 2105 of the California Rules of
Court.  In other cases, the parties may stipulate to the entry of
orders for the use of technology in conducting discovery.
   (2) An order authorizing that discovery may be made only upon the
express findings of the court or stipulation of the parties that the
procedures adopted in the order meet all of the following criteria:
   (A) They promote cost-effective and efficient discovery or motions
relating thereto.
   (B) They do not impose or require undue expenditures of time or
money.
   (C) They do not create an undue economic burden or hardship on any
person.
   (D) They promote open competition among vendors and providers of
services in order to facilitate the highest quality service at the
lowest reasonable cost to the litigants.
   (E) They do not require parties or counsel to purchase exceptional
or unnecessary services, hardware, or software.
   (3) Pursuant to these orders, discovery may be conducted and
maintained in electronic media and by electronic communication.  The
court may enter orders prescribing procedures relating to the use of
electronic technology in conducting discovery, including orders for
the service of requests for discovery and responses, service and
presentation of motions, production, storage, and access to
information in electronic form, and the conduct of discovery in
electronic media.  The Judicial Council may promulgate rules,
standards, and guidelines relating to electronic discovery and the
use of such discovery data and documents in court proceedings.
   (4) Nothing in this subdivision shall diminish the rights and
duties of the parties regarding discovery, privileges, procedural
rights, or substantive law.
   (5) If a service provider is to be used and compensated by the
parties, the court shall appoint the person or organization agreed
upon by the parties and approve the contract agreed upon by the
parties and the service provider.  If the parties do not agree on the
selection, each party shall submit to the court up to three nominees
for appointment together with a contract acceptable to the nominee
and the court shall appoint a service provider from among the
nominees.  The court may condition this appointment on the acceptance of modifications in the terms of the contract.  If no nominations
are received from any of the parties, the court shall appoint one or
more service providers.  Pursuant to noticed motion at any time and
upon a showing of good cause, the court may order the removal of the
service provider or vacate any agreement between the parties and the
service provider, or both, effective as of the date of the order.
The continued service of the service provider shall be subject to
review periodically, as agreed by the parties and the service
provider, or annually if they do not agree.  Any disputes involving
the contract or the duties, rights, and obligations of the parties or
service providers may be determined on noticed motion in the action.

   (6) Subject to these findings and the purpose of permitting and
encouraging cost-effective and efficient discovery, "technology," as
used in this section, includes, but is not limited to, telephone,
e-mail, CD-ROM, Internet web sites, electronic documents, electronic
document depositories, Internet depositions and storage,
videoconferencing, and other electronic technology that may be used
to improve communication and the discovery process.
   (7) Nothing in this subdivision shall be construed to modify the
requirement for use of a stenographic court reporter as provided in
paragraph (1) of subdivision (l) of Section 2025.  The rules,
standards, and guidelines adopted pursuant to this subdivision shall
be consistent with the requirement of paragraph (1) of subdivision
(l) of Section 2025 that deposition testimony be taken
stenographically unless the parties agree or the court orders
otherwise.
   (8) Nothing in this subdivision shall be construed to modify or
affect in any way the process used for the selection of a
stenographic court reporter.