Motion Types Legal Issues

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).

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).

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).

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.

Most Useful Motion to Compel Further Responses Examples

Recent Examples of Motion to Compel Further Responses

1-25 of 500 results

CLAIRE LEVINE VS SYLVESTER STEWART, ET AL.

...discovery and by not providing answers to legitimate interrogatories. The Court will allow Plaintiff to file a motion to compel further responses; if the Court finds in favor of Plaintiff on such a further motion, the Court will consider awarding plaintiff sanctions. Hopefully, the parties will be able to meet-and-confer to avoid the need for further motions on this issue. BACKGROUND: On February 26, 2019 Pl...

...malicious prosecution claim and overruled the demurrer to the SAC for the abuse of process claim. Before the Court is Plaintiff’s motion to compel verified responses, or in the alternative, compel further responses, to special interrogatories set one. ANALYSIS: A. Relevant Law Code of Civil Procedure requires a response from the party to whom requests for production are propounded within 30 days after service...

  • Hearing

    Feb 21, 2020

DEANNA AIVAZIAN VS. SARKIS TERSAKIAN ET AL

...Plaintiff: (1) a motion to compel initial responses to form interrogatories, set one (“FROG”), special interrogatories, set one (“SROG”), and requests for production of documents, set one (“RPD”); and (2) motion to deem the truth of matters specified in requests for admission, set one (“RFA”) admitted and conclusively established. On January 23, 2020, the Court denied Defendants’ “Ex Parte Application for an...

...Deed the Truth of Matters Admitted and Motion to Compel Response to Interrogatories and Request for Production”. The Court stated in its minute order that Plaintiff’s counsel represented that he provided responses to Defendants’ discovery requests. The Court’s minute order also reflected that Plaintiff’s counsel handed the discovery responses to defense counsel in open court. The Court encouraged defense counse...

  • Hearing

    Feb 21, 2020

CARRIEN QIAN HE, AN INDIVIDUAL VS JAY MIN CHEN, AN INDIVIDUAL, ET AL.

...PRODUCTION OF DOCUMENTS, SET ONE; (3) FOR RELEASE OF DOCUMENTS PURSUANT TO SUBPOENA DUCES TECUM. Responding Party: Defendant/Cross-Complainant, Jay Min Chen Tentative Ruling (1) The motion to compel further responses to special interrogatories is GRANTED. Defendant is ordered to serve verified further responses to Special Interrogatory Nos. 4 through 9, inclusive, within 20 days of this order. Plaintiff’s request ...

...sanctions is GRANTED in the amount of $960.00 against Defendant Jay Min Chen and his counsel of record, jointly and severally, to be paid within 30 days of this order. (2) The motion to compel further responses to request for production of documents is GRANTED as to Request for Production of Documents Nos. 1-4, 11-16, 18, 20-42, and 44, and DENIED as to Request for Production of Documents Nos. 5-10, 17, 19, ...

  • Hearing

    Feb 21, 2020

ROBERT S. SHUMAKE LIVING TRUST 1994 VS JASON Q. WILSON TRUST DATED OCTOBER 18, 2007 ET AL

Nature of Proceedings: (4) Motions to Compel TENTATIVE RULING: For the reasons set forth herein, the motions of defendant Louis Armstrong and Associates, LLC, to compel further responses to written discovery from plaintiff Robert S. Shumake Living Trust 1994 are continued to March 27, 2020, at 9:30 a.m. Background: On October 7, 2019, defendant Louis Armstrong and Associates, LLC, (...

...Shumake Trust, attorney Rafael Bernardino, Hobson, Bernardino & Davis LLP, filed his motion to be relieved as counsel. On November 25, 2019, following the granting of extensions, Shumake Trust served responses to the discovery in the form of objections. (E.g., Sandler decl. re special interrogatories, ¶¶ 3-5.) On December 6, 2019, counsel for LAA sent a meet and confer letter to counsel for Shumake Trust r...

  • Hearing

    Feb 21, 2020

SHELDON WIDUCH VS ANCHETA HOLDINGS LLC,, ET AL.

Sheldon Widuch v. Ancheta Holdings, LLC, et al. MOTION TO DEEM REQUESTS FOR ADMISSION ADMITTED WITHOUT OBJECTION AND FOR SANCTIONS AGAINST LAURA ANCHETA, ET AL, PURSUANT TO CCP SECTIONS 2023.010 & 2030.090 MOVING PARTY: Plaintiff Sheldon Widuch RESPONDI...

...rent. TENTATIVE RULING: Plaintiff Sheldon Widuch’s motion to deem RFAs admitted is DENIED. Plaintiff’s request for sanctions is also DENIED. Defendants’ request for sanctions is also DENIED. DISCUSSION: Motion To Deem RFAs Admitted When a party to whom requests for admission are directed fails to respond, the party propounding the requests may move for an order that the truth of any matters specified in th...

  • Hearing

    Feb 21, 2020

MARIA CANO VS GENERAL MOTORS, LLC, A DELAWARE LIMITED LIABILITY COMPANY

HEARING DATE: February 18, 2020 CASE NUMBER: 19STCV04011 CASE NAME: Maria Cano v. General Motors, LLC TRIAL DATE: March 24, 2020 MOTION: Motion to Compel Further Responses to Form Interrogatories MOVING PARTIES: Plaintiff, Maria Cano OPPOSING PARTY: Defendant, General Motors, LLC PROOF OF SERVICE: OK OPPOSITION: February 5, 2020 REPLY: February 11, 2020 TENTATIVE:...

...2020 TENTATIVE: Plaintiff’s motion to compel further responses to form interrogatories is GRANTED as to 1.1, 15.1 and 17.1 and otherwise denied. Plaintiff is to provide notice and GM is to provide further, verified responses within 20 days. MOTION: Motion to Compel Further Responses to Requests for Production MOVING PARTIES: Plaintiff, Maria Cano OPPOSING PARTY: Defendant, General Motors, LLC PROOF OF SERVICE: OK OPP...

  • Hearing

    Feb 20, 2020

IRMA MOJARRO ET AL VS CITY OF WHITTIER

...to Form Interrogatories (set two) is DENIED. III. Plaintiff’s Motion to Compel Further Responses to Request for Production of Documents (set four) is DENIED. IV. Plaintiff’s Motion to Compel Further Responses to Request for Production of Documents (set five) is DENIED. Opposing Party to give notice. “Except as provided in (b), any motion involving the content of a discovery request or the responses to su...

...separate statement. The motions that require a separate statement include a motion: (1) To Compel further responses to requests for admission; (2) To compel further responses to interrogatories…; (5) To compel or quash the production of documents or tangible things at a deposition…. (7) For issue or evidentiary sanctions.” (CRC Rule 3.1345(a).) “A separate statement is a separate document filed and served w...

  • Hearing

    Feb 20, 2020

CHARLES KUTA V. COLORTOKENS, INC.

...when Kuta separated from employment with ColorTokens. Defendant ColorTokens served several discovery requests on Kuta and has filed the instant motion to compel further discovery responses. The requested responses are targeted at discovering information regarding Linkaj, a competing company ColorTokens alleges Kuta and several of his coworkers created while they were still employed with ColorTokens. Kuta oppose...

...referenced during your July 30, 2019 deposition. Defendant ColorTokens requests further responses to all of the requests for production of documents listed above. A motion for an order compelling further responses “shall set forth specific facts showing good cause justifying the discovery sought by the inspection demand.” (Code Civ. Proc., §2031.310, subd. (b)(1); Kirkland v. Sup. Ct. (2002) 95 Cal.App.4th 92, ...

  • Hearing

    Feb 20, 2020

VICTORINO CASTILLO VS GLORIA'S COUNTRY BUTCHER, ET AL.

MOTION TO COMPEL FURTHER RESPONSES TO FORM INTERROGATORIES (CCP § 2030.300) TENTATIVE RULING: Plaintiff Jose Manzo’s Motion to Compel Further Answers to Interrogatories is CONTINUED TO MARCH 9, 2020 at 10:30 a.m. in Department 25. ...

...Defendant’s Answers to Interrogatories and Request for Sanctions and Motion to Compel Defendant’s Answers to Inspection Demands and Request for Sanctions. On January 30, 2020, at the hearing for these motions, Defendant argued that the discovery requests should be directed at his trust, not at him individually. The Court continued the hearing on the discovery motions and set an Order to Show Cause to veri...

  • Hearing

    Feb 20, 2020

MARTHA LETICIA AYON VS VOLKSWAGEN GROUP OF AMERICA INC ET AL

...BC719048 Plaintiff’s Motion to Compel Further Responses to Request for Production from Defendant Volkswagen Group of America, Inc.: the parties are ordered to meet and confer further prior to the hearing on the motion.

  • Hearing

    Feb 20, 2020

PERRIER VS. MARY'S PIZZA SHACK

HEARING ON MOTION TO COMPEL FURTHER RESPONSES FILED BY RORY PERRIER * TENTATIVE RULING: * Hearing continued by stipulation of the parties to March 19, 2020 at 9 a.m.

  • Hearing

    Feb 20, 2020

ESTATE OF RAYMOND BILL HARTMAN

Nature of Proceedings: Motion to Compel Further Responses from Julia Hartman This matter is continued to March 19, 2020 at 9:00 a.m. in Dept. 5. No appearance is required on February 20, 2020

  • Hearing

    Feb 20, 2020

ESTATE OF RAYMOND BILL HARTMAN

Nature of Proceedings: Motion to Compel Further Responses from Julia Hartman This amtter is continued to March 29, 2020 at 9:00 a.m. in Dept. 5. No appearance is required on February 20, 2020

  • Hearing

    Feb 20, 2020

ESTATE OF RAYMOND BILL HARTMAN

Nature of Proceedings: Motion to Compel Further Responses from Julia Hartman

  • Hearing

    Feb 20, 2020

EDWARD MAYO, AN INDIVIDUAL VS TK1SC, A CALIFORNIA CORPORATION

...things before a court, or at the trial of an issue therein, or at the taking of a deposition, the court, upon motion reasonably made by any person described in subdivision (b), or upon the court's own motion after giving counsel notice and an opportunity to be heard, may make an order quashing the subpoena entirely, modifying it, or directing compliance with it upon those terms or conditions as the court ...

...protect the person from unreasonable or oppressive demands, including unreasonable violations of the right of privacy of the person. (Code of Civ. Proc., § 1987.1(a).) There is no requirement that the motion contain a meet and confer declaration. (See Code of Civ. Proc., § 1987.1.) “Unless otherwise limited by order of the court . . . any party may obtain discovery regarding any matter, not privileged, t...

  • Hearing

    Feb 20, 2020

OSCAR RIDEAU VS SMART & FINAL LLC ET AL

... motion to compel further discovery responses to Plaintiff’s form interrogatories, set one is DENIED. No sanctions. Code of Civil Procedure section 2030.300 allows a party to file a motion compelling further answers to interrogatories if it finds that the response is inadequate, incomplete, or evasive, or an objection in the response is without merit or too general. The motion shall be accompanied with a ...

...to file a motion to compel further responses. (Clancey Decl., ¶ 9.) Thus, the court Cannot find that either party acted in good faith. Nonetheless, the Court is in receipt of Plaintiff’s supplemental responses to Defendant’s Form Interrogatories and finds that the responses are in substantial compliance. It is uncertain as to what basis Defendant seeks further responses when Plaintiffs already answered thes...

  • Hearing

    Feb 19, 2020

AURORA LEMERE, ET AL. VS LISA JEWETT, ET AL.

MOTION TO COMPEL FURTHER RESPONSES AND REQUEST FOR SANCTIONS (CCP § 2030.200) TENTATIVE RULING: Plaintiffs Aurora LeMere and Douglas B. Spoors’ Motions to Compel Further Responses are CONTINUED TO APRIL 30. 2020 at 10:30 a.m. in Department 25, SPRING STREET COURTHOUSE.. At least 16 court days before the next scheduled hearing, Plaintiffs must file and serve supplemental papers...

...Aurora LeMere and Douglas B. Spoors (collectively, “Plaintiffs”) filed the instant action for malicious prosecution, conspiracy, intentional infliction of emotional distress, and negligent infliction of emotional distress against Defendants Lisa Jewett, John Elliot, and Victoria Elliot (collectively, “Defendants”). On October 10, 2019, Plaintiffs filed the instant (1) Motion to Compel Further Responses from...

  • Hearing

    Feb 19, 2020

OSCAR RIDEAU VS SMART & FINAL LLC ET AL

...Stores, LLC’s motion to compel further discovery responses to Plaintiff’s form interrogatories, set one, is DENIED. No sanctions. Code of Civil Procedure section 2030.300 allows a party to file a motion compelling further answers to interrogatories if it finds that the response is inadequate, incomplete, or evasive, or an objection in the response is without merit or too general. The motion shall be accompa...

...a motion to compel further responses. (Clancey Decl., ¶ 9.) At the hearing, Defendant’s counsel explanation concerning the reason why the initial meet and confer letter was made three days before the motion filing deadline was unsatisfactory. While there is no hard and fast rule as to when the initial meet and confer outreach should be made within the 45-day period, the Court will not reward litigation t...

  • Hearing

    Feb 19, 2020

1998 AMPERSAND AVIATION LLC VS ESPERER HOLDINGS INC

...Proceedings: Compel Further Responses TENTATIVE RULING: Defendant’s motion to compel is granted. Plaintiff shall provide further, verified, responses to defendant’s RFA No. 2 and FI No. 17.1. The further responses shall be served on or before February 26, 2020. BACKGROUND: In these consolidated actions, plaintiff 1998 Ampersand Aviation, LLC (“Ampersand”) has sued for breach of contract in connection with two...

...October 24, 2019, Esperer propounded to Ampersand its Requests for Admission, Set Four, and its Form Interrogatories, Set Four. Ampersand served its responses on December 2, 2019. Esperer contends that the responses are deficient and now moves to compel further responses. Ampersand opposes the motion. ANALYSIS: Request for Judicial Notice In support of its discovery motion, Esperer requests that the court take...

  • Hearing

    Feb 19, 2020

ALMA D. MARQUEZ GUERRERO VS GENERAL MOTOR, LLC

...Perez’s MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE Responding Party: Defendant, FCA US LLC Tentative Ruling Plaintiff Fortino Guzman Perez’s Motion to Compel Further Responses to Plaintiff’s Request for Production of Documents, Set One is GRANTED as to Nos. 16-19 and 21 and is otherwise DENIED as MOOT. Background Plaintiff Fortino Guzman Perez (“Plaint...

...demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production. (CCP § 2031.220.) A motion to compel further responses to a demand for inspection or production of documents may be brought based on: (1) incomplete statements of compliance; (2) inadequate, evasive or incomplete representations of inability to comply; or...

  • Hearing

    Feb 19, 2020

GUADALUPE RODRIGUEZ, ET AL. VS RAY OF HOPE HOME INC., A CALIFORNIA CORPORATION

Plaintiff Guadalupe Rodriguez' Motion To Compel Further Responses To Form Interrogatories This motion was timely served and filed on November 18, 2019, which is prior to the November 19, 2019 deadline based upon Defendant’s mail service of responses on September 30...

...in the requested amount of $1,063.32. Sanctions are to be paid to Plaintiff’s counsel within 20 days. Plaintiff Guadalupe Rodriguez'Motion To Compel Further Responses To Requests For Admission This motion was timely served and filed on November 18, 2019, which is prior to the November 19, 2019 deadline based upon Defendant’s mail service of responses on September 30, 2019. Plaintiff’s counsel engaged ...

  • Hearing

    Feb 19, 2020

CARILYN ZAVALA VS. BDP MOBIL LLC

...Defendant BDP Mobil, LLC and (2) Defendant I.Asset Management, Inc.'s Motions to Compel Further Responses to Production, Set One. The court's tentative ruling is as follows: The court intends to deny both motions. Plaintiff has complied with CCP 2031.210 and its response is code-compliant.

  • Hearing

    Feb 19, 2020

1998 AMPERSAND AVIATION LLC VS ESPERER HOLDINGS INC

Nature of Proceedings: Compel Further Responses Tentative not yet posted, please check again.

  • Hearing

    Feb 19, 2020

CARRIEN QIAN HE, AN INDIVIDUAL VS JAY MIN CHEN, AN INDIVIDUAL, ET AL.

... Motions #1 and #2: OK[1] RE: He v. Chen, et al. (19PSCV00181) ______________________________________________________________________________ 1. Plaintiff Carrien Qian He’s MOTION TO COMPEL [FURTHER] RESPONSES TO REQUESTS FOR ADMISSIONS, SET ONE Responding Party: Defendant, Jay Min Chen[2] 2. Plaintiff Carrien Qian He’s MOTION TO COMPEL [FURTHER] RESPONSES TO FORM INTERROGATORIES, SET ONE Responding Part...

...Jay Min Chen 3. Plaintiff’s Carrien Qian He’s MOTION FOR PRELIMINARY INJUNCTION Responding Party: Defendant, Jay Min Chen. Tentative Ruling 1. Plaintiff Carrien Qian He’s Motion to Compel Further Responses to Requests for Admissions, Set One is GRANTED. Chen ordered to provide further, verified responses to Plaintiff’s Requests for Admissions, Set One within 15 days. Sanctions are awarded against Che...

  • Hearing

    Feb 18, 2020

ANA TORRES, ET AL. VS FCA US, LLC, A DELAWARE LIMITED LIABILITY COMPANY

...(1) Motion to Compel Further Responses to Form Interrogatories (2) Motion to Compel Further Responses to Special Interrogatories (3) Motion to Compel Further Responses for Production of Documents (4) Motion to Compel Further Responses to Form Interrogatories Moving Party: Plaintiffs Ana Torres and Manuel Cortez Resp. Party: Defendant FCA US, LLC The Court orders the parties to attend an Informal Disco...

...the instant motions to compel further discovery responses to production of documents, special interrogatories, form interrogatories, and requests for admission. ANALYSIS: Plaintiff moves for an order compelling Defendant to provide further responses to (1) Form Interrogatories, Nos. 1.1, 12.1, and 17.1; (2) Special Interrogatories, Nos. 1, 14, 26, 27, 41, 42, 43, 45, 46, 51, 52, and 53; (3) Request for P...

  • Hearing

    Feb 18, 2020

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