I sent special interrogatories and requests for admission to defendants. They responded with objections only. I know that in order for me to compel further responses I need to meet and confer with the defendant's attorney.
Can I contact him by email and request a meeting? Also, for this meeting, am I obligated to go to his office or can I request him to meet in the middle of way between us for example in a public library (since I don't have an office) and can I conduct this meeting over the phone rather than meeting in person? Is there a specific protocol to follow during this meeting or is it just an open conversation? Can they or me record this conversation?