Extract to table

If Aldrich possesses a term sheet, a draft agreement, an email chain discussing deal terms, or any other document reflecting an actual or contemplated co-production arrangement with Halcyon Creek, he must produce it

) The motion must set forth specific facts showing good cause justifying the discovery sought by the demand

) The motion must also be accompanied by a meet-and-confer declaration under Code of Civil Procedure section 2016

) Where a party asserts a privacy objection to a discovery request, the court must balance the right to privacy against the compelling need for the discovery

) Where the information sought is directly relevant to the claims and defenses in the action, and where a protective order is in place to prevent unnecessary dissemination, the privacy objection must yield

3d 844, 859 [privacy rights must "bend" to accommodate compelling discovery needs]; see also Valley Bank of Nevada v