I am a paralegal and am working on a problem for a client.  This is a
case in California.  I need to know what grounds there are for
re-opening discovery.  The defendant and defendant?s attorney have
been delinguent, refusing to respond to discovery.  This includes
ignoring notices of deposition and refusing to attend the mediation.

The statute seems vague on the subject.  What I would really like to
know is if there is any relevant case law on the subject.

Sorry I can?t pay much.  Any help anyone could provide would be most appreciated.

If you are working for a client then in the end, the client pays.  And
the client will get what they pay for.  Perhaps this case should be
handled by an attorney.
If the defendants have not responded to any requests for discovery
what is there to reopen?  The next step would be a hearing in front of
a judge for them to explain why they have not responded.

Perhaps I did not make myself clear.  First of all, my client IS an
attorney and we are working on the problem.  The deadline for
discovery has passed and we are researching what grounds there are for
reopening.  We are particularly interested in case law and anybody's
experience.