What is a Motion to Compel Further Responses to Interrogatories?

“Any party may obtain discovery... by propounding to any other party to the action written interrogatories to be answered under oath.” Code Civ. Proc., § 2030.010(a).

The Code of Civil Procedure, section 2030.210(a) provides, "The party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by any of the following:

  1. An answer containing the information sought to be discovered.
  2. An exercise of the party's option to produce writings.
  3. An objection to the particular interrogatory.

The Code of Civil Procedure, section 2030.260(a) provides,

Within 30 days after service of interrogatories, the party to whom the interrogatories are propounded shall serve the original of the response to them on the propounding party....

The Code of Civil Procedure, section 2030.270(a) explains,

The party propounding interrogatories, and the responding party may agree to extend the time for service of a response to a set of interrogatories.... (b) The agreement may be informal, but it shall be confirmed in a writing that specifies the extended date for service of a response.

The Code of Civil Procedure, section 2030.290 states,

If a party to whom interrogatories are directed fails to serve a timely response, the following rules apply:... The party propounding the interrogatories may move for an order compelling response to the interrogatories.

A protective order may be granted on a noticed motion of a party who is served with interrogatories. CCP § 2030.090(a). The motion must be accompanied by a declaration stating facts showing a “reasonable and good faith attempt” to resolve the matter outside of court. Code Civ. Proc. § 2030.090(a).

If a propounding party is not satisfied with the response served by a responding party, he may move the court to compel further interrogatory responses. Code Civ. Proc. § 2030.300; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 403. The propounding party must demonstrate that the responses were incomplete, inadequate or evasive, or that the responding party asserted objections that are either without merit or too general. Code Civ. Proc. § 2030.300(a)(1)–(3); Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 403.

The propounding party must, in addition, establish that it complied with its obligation to “meet and confer.” Code Civ. Proc. §§ 2016.040, 2030.300(b); Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 403.

Furthermore, the propounding party is required to file a Separate Statement that sets forth each item to which further response is requested and the factual and legal reasons for compelling it, as specified in CRC 3.1345(c). See Sinaiko Healthcare Consulting, Inc., supra, 148 Cal.App.4th at 403.

The Code of Civil Procedure section 2030.030 limits the number of interrogatories that can be propounded to 35. §2030.090(b)(2) permits a party receiving interrogatories in excess of 35 to move for a protective order limiting the interrogatories to 35. But the Code of Civil Procedure section 2030.040 permits a party to propound more than 35 special interrogatories with a declaration of necessity.

Useful Rulings on Motion to Compel Further Responses to Interrogatories

Recent Rulings on Motion to Compel Further Responses to Interrogatories

1-25 of 10000 results

ALOSTA ASSOCIATES, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY VS MICHAEL P. JABLONSKI

Plaintiff's motions to deem plaintiff's request for admissions admitted and plaintiff's motion to compel defendant to respond to special interrogatories, set one, are GRANTED. Defendant is ordered to respond to the special interrogatories, set one, within 30 days. Sanctions in the total amount of $1,173.30 is ordered to be paid by defendant to plaintiff within 30 days.

  • Hearing

    Oct 06, 2020

  • Type

    Real Property

  • Sub Type

    Landlord Tenant

KEVIN T. SMITH VS PATRICK PHILIP

The court awards Defendant one hour for preparing each form motion to compel and one hour to appear at the hearing- but awards this time only once- all at the requested rate of $100 per hour, for a total attorney’s fees award of $500. The court also awards four filing fees of $60 each, or $240 in costs. Sanctions are sought and imposed against Plaintiff, who is in pro per.

  • Hearing

    Oct 06, 2020

PAULA KLEIN VS PQ ENCINO BAKERY, INC. DBA LE PAIN QUOTIEN, ET AL.

(“Defendant”) moves to compel responses from Plaintiff Paula Klein (“Plaintiff”) to: (1) Request for Production of Documents, Set Two (“RPD”); (2) Form Interrogatories, Set Two (“FROG”); and (2) Special Interrogatories, Set Two (“SROG”). Defendant also moves to deem the matters specified in the Requests for Admission, Set One (“RFAs”) to have been admitted. The Court notes that Defendant filed one motion to compel responses to the RFAs FROG, and SROG.

  • Hearing

    Oct 05, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

MASSE VS. FRUEHAN

Motion to Compel Responses to Form Interrogatories 2. Motion to Compel Responses to Form Interrogatories 3. Motion to Compel Responses to Form Interrogatories 4. Motion to Compel Responses to Form Interrogatories 5. Motion to Deem Admitted the Truth of Matters Specified in Request for Admissions, Set One. Moving Party Defendants Joel Fruehan and Annette Fruehan. Responding Party Amy Vrooman.

  • Hearing

    Oct 05, 2020

630 SOUTH GRAND AVE LLC, A CALIFORNIA LIMITED LIABILITY COMPANY VS ARDASHIR FAROKHIRAD, ET AL.

Plaintiff’s remedy, then, was not to file a straightforward motion to compel, but a motion to compel furthers. Since a response to the subject discovery was made, the motion is denied as moot. Sanctions The court declines Plaintiff’s request for sanctions. 2. Motion to Compel Form Interrogatories Re: Farokhirad Legal Standard See Motion #1. Discussion Plaintiff moves the court for an order compelling Farokhirad to provide responses to Plaintiff’s Form Interrogatories, Set No.

  • Hearing

    Oct 02, 2020

  • Type

    Real Property

  • Sub Type

    Landlord Tenant

LILIA RIOS, ET AL. VS EDGAR G. VILLAMARIN

THE MOTION TO COMPEL FURTHER REQUEST FOR ADMISSIONS IS GRANTED. THE MOTION TO COMPEL FURTHER FORM INTERROGATORIES IS GRANTED. DATE: _______________ _______________________________ JUDGE

  • Hearing

    Oct 02, 2020

JACOB HILL VS THE CANYON LAKE PROPERTY OWNERS ASSOCIATION, ET AL.

Motion to Compel Plaintiff to Produce Verified Responses, Without Objections, to Defendant’s Form Interrogatories, Set One; Special Interrogatories, Set One; Request for Production of Documents, Set One; and Requests for Admission, Set One and Request for Monetary Sanctions is DENIED.

  • Hearing

    Oct 02, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

HUNTER VS. INTERNATIONAL TOWING, INC.

Defendants Newport Condominium Association and Powerstone Property Management, Inc.’s unopposed Motion to Compel Plaintiff Rachel [sic] Hunter to Provide a Further Response to Form Interrogatories is granted. Plaintiff Ruby Hunter is ordered to serve a verified supplemental response to Form Interrogatory No. 17.1 of defendants’ Form Interrogatories, Set Two, as to defendants’ Request for Admission #21-33 and 35-37, without objections, within 20 days.

  • Hearing

    Oct 02, 2020

KAIRI HARVIG VS VALERIO CHIAROTTI

TO COMPEL FURTHER REQUEST FOR ADMISSIONS IS DENIED.

  • Hearing

    Oct 02, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

SOLEDAD GOMEZ VS RODOLFO SEGUNDO ULLOA

The court awards one hour for preparing each form motion to compel and one hour to appear at the hearing- but awards this time only once- all at the rate of $143.75 per hour. The court awards three motion filing fees of $60 each, or $180 in costs. While Defendant requests a $94 CourtCall fee, the court notes the cost to appear remotely through LACourtConnect is $15, and thus, awards Defendant the $15 fee. Sanctions are sought against Plaintiff and Plaintiff’s attorney of record.

  • Hearing

    Oct 02, 2020

LORENA ROMERO VS WESTERN PLAZA PROPERTIES, LLC.

CASE NO: 19STCV39176 [TENTATIVE] ORDER RE: MOTION TO COMPEL RESPONSES Dept. 31 1:30 p.m. October 2, 2020 Defendant, Western Plaza Properties, LLC filed its motion to compel responses to form interrogatories on 5/20/20. Based on current conditions, including, but not limited to, the spread of COVID-19, the court set this matter to be heard on 10/02/20 and ordered the moving party, Defendant, to give notice of the hearing date. (Minute Order 5/21/20.)

  • Hearing

    Oct 02, 2020

SUPERIOR COURT VS. MELISSA EREZO

On 20 July 2020, Defendant/Cross-Complainant filed this motion to compel further responses to interrogatories, request for production of documents and for monetary sanctions. No opposition papers were filed. II. Analysis. A. Motion to Compel Further Responses. A party who is dissatisfied with responses to discovery may file a motion to compel further responses.

  • Hearing

    Oct 01, 2020

BUNK V. MOLNAR

Continued Hearing on Motion to Compel Further Discovery Responses and for Sanctions filed by Plaintiffs and Supplemental Motion to Compel Further Discover Responses and for Sanctions filed by Plaintiffs TENTATIVE RULING There have been orders and findings made by another judge earlier on these motions, as to matters such as the untimeliness of the responses served by Defendant BEN MOLNAR (“BEN”) to the subject form interrogatories and requests for production, and restricting the scope of the document requests

  • Hearing

    Oct 01, 2020

LUIS TORRES VS RENE BUENO, ET AL.

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) Having considered the moving, opposing, and reply papers, the Court rules as follows. BACKGROUND On January 30, 2020, Plaintiff Luis Torres (“Plaintiff”) filed a complaint against Defendants Rene Bueno and United Site Services, Inc. (erroneously sued and served as Unitesite Services) (“Defendant United”).

  • Hearing

    Oct 01, 2020

SILVA VS. THE GLORIA J PARKER TRUST

Based on the above, the Motion to Compel Responses to Form Interrogatories (Set One) and Request for Production of Documents (Set One) is GRANTED. Pham is ordered to provide verified responses, without objection, to Plaintiff’s Form Interrogatories (Set One) and Request for Production of Documents (Set One) within 30 days of the date of service of the notice of this order. Plaintiff to give notice.

  • Hearing

    Oct 01, 2020

DAVID AZIZI VS. BEHNAM RAFALIAN, ET AL.

If a timely motion to compel has been filed, the burden is on the responding party to justify any objection or failure fully to answer. (Coy v. Superior Court (1962) 58 Cal.2d 210, 220–221 [addressing a motion to compel further responses to interrogatories]; see also Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.) Analysis Discovery timeline The timeline of discovery is important for the disposition of these motions. Azizi served his form interrogatories, set one, on November 4, 2019.

  • Hearing

    Oct 01, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

  • Judge

    Maurice A. Leiter or Salvatore Sirna

  • County

    Los Angeles County, CA

ISMAEL ZAMORA VS AMERICAN HONDA MOTOR CO., INC.

The trial court might compel responses without objection if it finds no legally valid responses have been provided to one or more interrogatories; it might deny the motion to compel responses as essentially unnecessary, in whole or in part, and just impose sanctions; it might treat the motion as one under section 2030.300 and either determine that further answers are required, or order the propounding party to “meet and confer” (§ 2030.300, subd. (b)) and file a separate statement (Cal.

  • Hearing

    Oct 01, 2020

ARMANDO TORRES, ET AL. VS CARLOS A. TURCIOS DURAN

CASE NO: 19STCV24384 [TENTATIVE] ORDER GRANTING MOTION TO COMPEL FURTHER RESPONSES Dept. 31 10:00 a.m. October 1, 2020 Background Plaintiffs, Armando Torres and Samantha Silva filed this action against Defendant, Carlos A. Turcios Duran for damages arising from a motor for damages arising from a motor vehicle accident. On 4/30/20, Plaintiffs filed the instant motions to compel further responses to form interrogatories, set one, and request for admissions, set one.

  • Hearing

    Oct 01, 2020

DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING VS. PATHWAYS COMMUNITY SERVICES, LLC

Accordingly, the Court GRANTS the motion to compel further responses to Special Interrogatory Nos. 21, 22, 23, 24, 25, and 26 on condition that a prior notice, pursuant to Belaire-West is sent to the employees offering them an opportunity to opt out of disclosure. Motion #2 Plaintiff Department of Fair Employment and Housing moves for an order compelling defendant Pathways Community Services, LLC to provide further responses to Requests for Production Nos. 10, 12, 28, 50, 57, 58, 59, 68.

  • Hearing

    Oct 01, 2020

SPILMAN V. SPENCE, ET AL.

Superior Court (1998) 67 Cal.App.4th 424 [factors to be considered include the complexity of the discovery issues, the past history of the counsel on prior disputes, and to a certain extent, the judge's gut feeling; sending one brief letter 13 days prior to the deadline to file a motion to compel further responses did not constitute a sufficient "meet and confer" attempt].

  • Hearing

    Oct 01, 2020

JOHN MILLER, ET AL. VS MARTIN D. GROSS, ET AL.

Gross) moves to compel Plaintiff to provide responses to form and special interrogatories, set one. This motion should have been reserved and filed as two separate motions: (1) motion to compel responses to form interrogatories; and (2) motion to compel responses to special interrogatories, and requests sanctions. Combining multiple motions under the guise of one motion with one hearing reservation manipulates the Court Reservation System and unfairly jumps ahead of other litigants.

  • Hearing

    Oct 01, 2020

REID VS. CATULLO

Motion to Compel Answers to Form Interrogatories filed by Plaintiff Garth Reid as to Defendant Daniel E. Catullo III 2. Motion to Compel Answers to Form Interrogatories filed by Plaintiff Garth Reid as to Defendant The City Drive Group, LLC 3. Motion to Compel Answers to Form Interrogatories filed by Plaintiff Garth Reid as to Defendant The City Drive Films, LLC 4. Motion to Compel Answers to Special Interrogatories filed by Plaintiff Garth Reid as to Defendant Daniel E. Catullo III 5.

  • Hearing

    Oct 01, 2020

SERRANO CREEK VILLAS HOMEOWNERS ASSOCIATION V. MAREVICI

B) Motion to Compel Responses to FROGS Plaintiff’s unopposed Motion to Compel Responses to FROGS from Defendant is GRANTED. Defendant was required to serve verified responses to the Discovery no later than 05/14/20, but has apparently failed to serve any responses whatsoever. CCP §§ 2030.260(a) and 1013. The present motion is proper and therefore granted. CCP § 2030.290. Defendant is ordered to serve verified responses to the FROGS within 15-days of service of notice of the Court’s ruling.

  • Hearing

    Oct 01, 2020

SANCHEZ VS. ARB, INC.

Motion to Compel Supplemental Interrogatories: With respect to Supplemental Interrogatories Nos. 13, 14, 16, 18, 19, 25, 26, 29, 33, 34, 36 and 37, the Motion has been withdrawn. (See Reply: 6:8-9). With respect to Supplemental Interrogatories Nos. 15, 17, 20 and 24, consistent with the Joint Statement filed on September 18, 2020, Defendant shall “provide further responses to these interrogatories that encompasses all unions/class members by no later than October 9, 2020.” (Joint Statement: 5:6-7).

  • Hearing

    Oct 01, 2020

CHAD SNOW, ET AL. VS TARA FOLEY

LEGAL STANDARD If a party to whom interrogatories are directed fails to serve a timely response, the propounding party may move for an order compelling responses and for a monetary sanction. (Code Civ. Proc., § 2030.290, subd. (b).) The statute contains no time limit for a motion to compel where no responses have been served.

  • Hearing

    Oct 01, 2020

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