What is a Motion to Compel Further Responses?

A party may move to compel further responses to interrogatories on the grounds that the answer is evasive or incomplete, an exercise of the option to produce documents under the Code of Civil Procedure, section 2030.230 is unwarranted or the required specification of those documents is inadequate, and/or an objection to an interrogatory is without merit or too general. (Code Civ. Proc. § 2030.300(a).)

How to Structure the Motion

A motion to compel further responses to interrogatories must include a meet and confer declaration pursuant to the Code of Civil Procedure, section 2016.040 and a separate statement. (Code Civ. Proc. § 2030.300(b); Cal. Rules of Ct., Rule 3.1345.)

The separate statement must provide “all the information necessary to understand each discovery request and all responses to it that are at issue. The separate statement must be full and complete so that no person is required to review any other document in order to determine the full request and the full response... The separate statement must include... the following:

  1. The text of the request, interrogatory, question, or inspection demand;
  2. The text of each response, answer, or objection, and any further responses or answers;
  3. A statement of the factual and legal reasons for compelling further responses, answers, or production as to each matter in dispute;
  4. If necessary, the text of all definitions, instructions, and other matters required to understand each discovery request and the responses to it;
  5. If the response to a particular discovery request is dependent on the response given to another discovery request, or if the reasons a further response to a particular discovery request is deemed necessary are based on the response to some other discovery request, the other request and the response to it must be set forth; and
  6. If the pleadings, other documents in the file, or other items of discovery are relevant to the motion, the party relying on them must summarize each relevant document.”

(Rules of Ct., Rule 3.1345(c).)

Response

If a timely motion to compel has been filed, the burden is on the responding party to justify any objection or failure to fully answer the interrogatories. (Fairmont Ins. Co. v. Super. Ct. (2000) 22 Cal.4th 245, 255.)

Timeline

Notice of the motion must be “given within 45 days of the service of the verified response, or any supplemental verified response, or on or before any specific later date to which the propounding party and the responding party have agreed in writing.” (Code Civ. Proc. § 2030.300(c).)

Useful Rulings on Motion to Compel Further Responses

Recent Rulings on Motion to Compel Further Responses

1-25 of 10000 results

TAULER SMITH LLP VS JOSEPH VALERIO, ET AL.

No separate statement was filed in connection with the Motion to Compel Further Responses. Next, the court addresses the fact that Plaintiff has filed a single discovery motion to compel further responses with respect to eight separate sets of discovery (four sets of discovery as to two Defendants). Yet Plaintiff has only paid a single filing fee.

  • Hearing

    Sep 22, 2020

  • County

    Los Angeles County, CA

LESLIE SPANN VS ELAINE WAILING CHU

CASE NO: 19STCV25852 [TENTATIVE] ORDER RE: MOTION TO COMPEL FURTHER RESPONSES Dept. 31 3:30 p.m. September 22, 2020 Background Plaintiff, Leslie Spann filed this action against Defendant, Elaine Wailing Chu for damages arising from a motor vehicle accident. On 1/21/20, Plaintiff filed the motion to compel further responses to Plaintiff’s request for production of documents (“RPDs”), set one.

  • Hearing

    Sep 22, 2020

BEYER VS. ALI

Motion 1: Motion to Compel Further Responses to Form Interrogatories, Set One. Moving Party Defendant Orange Coast Memorial Medical Center (“OCMMC”). Responding Party Plaintiff Paul H. Beyer. Ruling: Defendant OCMMC’s motion to compel further responses to Form Interrogatories, Set One is granted.

  • Hearing

    Sep 21, 2020

BARRY KELLMAN VS TITLE RECOVERY SERVICES, LLC, ET AL.

On September 8, 2020, Defendants filed oppositions to the motions to compel further responses to Requests for Production and Special Interrogatories and a supporting declaration. Akinyemi did not file an opposition to the motion to compel further responses to Form Interrogatories. In addition, Defendants did not file separate statements in support of their oppositions addressing Plaintiff’s argument compelling a further response and supporting their objections to the requests.

  • Hearing

    Sep 21, 2020

CAMPUZANO VS. CONTRERAS

Motion to Compel Further Responses to Form Interrogatories 2. Motion to Compel Responses to Request for Admissions Moving Party: Plaintiff Eduardo Campuzano Responding Party: Defendants Mariana and Norma Contreas Ruling: Plaintiff Eduardo Campuzano’s Motion to Compel Further Responses to Form Interrogatories and Requests for Admission is GRANTED. Within twenty (20) days, Defendants shall respond without objection to the discovery. Plaintiff’s Request for Sanctions is DENIED.

  • Hearing

    Sep 21, 2020

MIDLAND ENTERTAINMENT LLC VS HYDRA GROUP LLC ET AL

Defendant and Cross-Complainant Third Floor Inc.’s Motion to Compel Further Responses to Requests for Production is GRANTED as to Request No. 33. Defendant Joel Newton’s Motion for Attorney Fees is GRANTED in the amount of $45,000. Defendant to provide notice. ATTORNEY FEES AGREEMENT Newton asks for $45,000 in attorney fees pursuant to an agreement. (Motion at p. 1.) A prevailing part is entitled to an award of costs (Code Civ. Proc. § 1032, subd.

  • Hearing

    Sep 21, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

CAMPUZANO VS. CONTRERAS

Motion to Compel Further Responses to Form Interrogatories 2. Motion to Compel Responses to Request for Admissions Moving Party: Plaintiff Eduardo Campuzano Responding Party: Defendants Mariana and Norma Contreas Ruling: Plaintiff Eduardo Campuzano’s Motion to Compel Further Responses to Form Interrogatories and Requests for Admission is GRANTED. Within twenty (20) days, Defendants shall respond without objection to the discovery. Plaintiff’s Request for Sanctions is DENIED.

  • Hearing

    Sep 21, 2020

GOLDEN RAIN FOUNDATION OF LAGUNA WOODS V. DICKINSON

Motion to Compel Further Responses to Special Interrogatories, Set Two – GRANTED The Motion by Cross-Defendants Golden Rain Foundation of Laguna Woods and Village Management Services, Inc. to Compel Cross-Complainant Alan Dale Dickinson (“Cross-Complainant” or “Dickinson”) to provide further verified responses to their Special Interrogatories, Set Two is granted.

  • Hearing

    Sep 21, 2020

SOLTER V. WU

1) Motion to Compel Further Responses to Form Interrogatories 2) Motion to Compel Further Responses to Special Interrogatories CONTINUED TO 9/28/20

  • Hearing

    Sep 21, 2020

ROSY M ROSALES VS NISSAN NORTH AMERICA, INC.

Rosales’ MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE Responding Party: Defendant Nissan North America, Inc.[2] Tentative Ruling Plaintiff Rosy M. Rosales’ Motion to Compel Further Responses to Plaintiff’s Request for Production of Documents, Set One is DENIED as to Requests Nos. 7 and 10 and is otherwise GRANTED.

  • Hearing

    Sep 21, 2020

PIAZZA V. THE IRVINE COMPANY APARTMENT COMMUNITIES, INC.

Motion to Compel Further Responses to Form Interrogatories 4. Motion to Compel Response to Requests for Admissions All CONTINUED to November 2, 2020 at 1:30 p.m. to permit the Court and parties to conduct an Informal Discovery Conference.

  • Hearing

    Sep 21, 2020

CHRISTOPHER RODRIGUEZ VS JIMMY DULANEY

.: 19STCV35313 Hearing Date: September 21, 2020 [TENTATIVE] order RE: MOTIONS TO COMPEL FURTHER RESPONSES Plaintiff filed motions to compel further responses to Form Interrogatories, Set One; Special Interrogatories, Set One; and Requests for Production, Set One. There are numerous defects with Plaintiff’s motions. First, no proofs of service were filed with the motions, so the Court does not know whether they were served when they were filed.

  • Hearing

    Sep 21, 2020

HELEN CRUCHFIELD CHRISTONI VS PRETTYPARTY BEAUTY, LLC., ET AL.

Before the Court is a hearing on Steven and Laura’s separate motions to compel further responses to special interrogatories. On March 15, 2019, Plaintiff filed her initial complaint.

  • Hearing

    Sep 21, 2020

  • Type

    Employment

  • Sub Type

    Other Employment

WHITTAKER VS. LAGO

The motion by Plaintiff William Whittaker to compel further responses from Defendant Alexandra Lago to Special Interrogatories (Set Two) is CONTINUED to 10/09/2020 at 10:00 a.m. in Department C24. Should Defendant wish to address the additional evidence submitted by Plaintiff on reply, Defendant shall file and serve a supplemental brief of no more than five pages on or before 10/02/2020. No additional evidence will be considered. Plaintiff to give notice. Motion No. 2.

  • Hearing

    Sep 18, 2020

INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB VS. HILL

Motion to Compel Further Responses to Special Interrogatories 4. Motion to Compel Production 5. Motion to Compel Deposition (Oral or Written) 6. Motion to Compel Deposition (Oral or Written) 7. Motion to Compel Response to Requests for Admissions This matter is continued. Clerk to give notice.

  • Hearing

    Sep 18, 2020

DARSHAN THIND VS MUKHTIAR S KAMBOJ ET AL

On February 4, 2020, Plaintiff moved to compel further responses to discovery, including: (1) Motion to Compel Mukhtiar Kamboj’s Amended Responses to Requests for Admission, Set 1; (2) Motion to Compel Mukhtiar Kamboj’s Amended Responses to Form Interrogatories, Set 1; (3) Motion to Compel Mukhtiar Kamboj’s Amended Responses to Special Interrogatories, Set 1; (4) Motion to Compel Mukhtiar Kamboj’s Amended Responses to Requests for Production of Documents, Set 1; (5) Motion to Compel Amadeep Kamboj’s Amended

  • Hearing

    Sep 18, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

BEDIRIAN ENTERPRISES, INC. VS LEONID KAMENETSKY, ET AL.

.: 19STCV42522 Hearing Date: September 18, 2020 [TENTATIVE] order RE: motion to compel further responses to request for production of documents, SET ONE The Court finds Plaintiffs’ discovery to be overly broad and unduly burdensome. The Court issues the following discovery order: Defendant American Honda Motor Co, INC.

  • Hearing

    Sep 18, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

FRANCISCO ROCHA VS ERIC CHAPMAN ET AL

Responding Party: Defendant Lemoli Avenue HOA (1) Motion to Compel Further Responses to Form Interrogatories, Set One (2) Motion to Compel Further Responses to Request for Production, Set One (3) Motion to Compel Further Responses to Request for Admissions, Set One The court considered the moving, Lemoli’s counsel’s declaration, and reply papers. RULING The motions are GRANTED.

  • Hearing

    Sep 18, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

YAKIR Y COHEN VS NISSAN NORTH AMERICA, INC.

Based on the foregoing, Plaintiff’s Motion to Compel Further Responses is GRANTED in part.

  • Hearing

    Sep 18, 2020

  • Judge

    Paul A. Bacigalupo or Virginia Keeny

  • County

    Los Angeles County, CA

JESSICA P LOREDO DE LUCAS VS NISSAN NORTH AMERICA, INC.

This includes a motion to compel further responses to demand for inspection of documents or tangible things. CRC Rule 3.1020(a)(3).

  • Hearing

    Sep 18, 2020

ANDREW MCGINNIS, ET AL. VS SAN MARINO GARDENS WELLNESS CENTER, LP

Sanctions Plaintiff seeks monetary sanctions in connection with the motion to compel further responses to interrogatories, but does not seek sanctions in connection with the motion related to document demands.

  • Hearing

    Sep 18, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

JACOBS V. MARION, ET AL.

A party may move to compel further responses to interrogatories on the grounds that the answer is evasive or incomplete, an exercise of the option to produce documents under Code of Civil Procedure section 2030.230 is unwarranted or the required specification of those documents is inadequate, and/or an objection to an interrogatory is without merit or too general. (Code Civ. Proc., § 2030.300, subd. (a).)

  • Hearing

    Sep 18, 2020

GEORGE GOMEZ VS AXALTA COATING SYSTEMS, LLC, ET AL.

MOTION TO COMPEL FURTHER RESPONSES TO BUSINESS RECORDS SUBPOENA [CCP §2025.480] APPLICATIONS FOR PRO HAC VICE ADMISSION (3) [CRC 9.40] Date: 9/18/20 (2:00 PM) Case: George Gomez v. Axalta Coating Systems, LLC et al. (19GDCV01380) TENTATIVE RULING: I. DEFENDANT PPG INDUSTRIES, INC.’S MOTION TO STRIKE PORTIONS OF PLAINTIFF’S COMPLAINT Defendant PPG Industries, Inc.

  • Hearing

    Sep 18, 2020

PARSIG CHOULJIAN VS TOTAL RENAL CARE INC.

As such, the motion to compel further responses to RPD Nos. 1-3 and 6 is denied. Plaintiff should limit the scope of his RPD requests to seek information relevant to this action. 3.

  • Hearing

    Sep 18, 2020

  • Type

    Employment

  • Sub Type

    Wrongful Term

  • County

    Los Angeles County, CA

CARMEN LIZA VS CKE RESTAURANTS HOLDINGS INC

A motion to compel further responses “shall be accompanied by a meet and confer declaration.” (Code Civ. Proc., § 2031.310, subd. (b)(2).) Defendant asserts that there was no communication from Plaintiff regarding this motion. The failure to meet and confer and to file a declaration confirming a meet and confer is a ground to deny a discovery motion.

  • Hearing

    Sep 18, 2020

  • Type

    Employment

  • Sub Type

    Wrongful Term

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