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

SAE GLOBAL LOGISTICS LTD. VS RICHARD TSIU, ET AL.

Plaintiff Sae Global Logistics Ltd.’s MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S SPECIAL INTERROGATORIES, SET TWO Responding Party: Non-Party, Laura Each Nguyen (i.e., former counsel for Defendant Richard Tsiu) 2. Plaintiff Sae Global Logistics Ltd.’s MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET TWO Responding Party: Non-Party, Laura Each Nguyen (i.e., former counsel for Defendant Richard Tsiu) Tentative Ruling 1. & 2. See below.

  • Hearing

    Jul 09, 2020

  • Type

    Business

  • Sub Type

    Intellectual Property

SAE GLOBAL LOGISTICS LTD. VS RICHARD TSIU, ET AL.

OSC Re Sanctions: Laura Each Nguyen Ordered to Appear The Court also ordered that Plaintiff’s [sic] prior counsel Laura Each Nguyen personally at [sic] an OSC Re: the award of discovery sanctions against her regarding the Plaintiff’s Motions to compel $1,689.00 (Re: Motion to Compel Responses to Special Interrogatories Set 2); $1,800.00 (Re: Motion to Compel Responses to Requests for Production Set 2); $1,350.00 (Re: Motion to Compel Responses to Requests for Production Set 1) against pursuant [sic] to CCP

  • Hearing

    Jul 09, 2020

  • Type

    Business

  • Sub Type

    Intellectual Property

JANE MI VS HOSSEIN ZAHED ZADEH

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

    Jul 08, 2020

ABEL VALDEZ VS AUGUSTO ROJAS, ET AL.

CONCLUSION AND ORDER Defendant’s motion to compel responses to the FROG is granted per Code of Civil Procedure section 2030.290. Plaintiff shall serve verified responses, without objections, within thirty (30) days of notice of this order. Defendant’s motion to deem the matters specified in the RFAs to have been admitted is granted. Plaintiff is deemed to have admitted the truth of all such matters.

  • Hearing

    Jul 08, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Medical Malpractice

FRIDA KORSHUNOVA VS 1116 MAPLE STREET, LLC

.: 19STCV07557 Hearing Date: July 8, 2020 [TENTATIVE] order RE: motion to compel discovery responses Defendant 1116 Maple Street, LLC (“Defendant”) moves to compel responses from Plaintiff Frida Korshunova (“Plaintiff”) to Special Interrogatories (“SROG”), Sets Three and Four. Defendant served SROG, Set Three, on Plaintiff by mail on January 21, 2020. Defendant served SROG, Set Four, on Plaintiff by mail on January 27, 2020.

  • Hearing

    Jul 08, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

ASHLEY KING VS MIGUEL CASTRO

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

    Jul 07, 2020

SAE GLOBAL LOGISTICS LTD. VS RICHARD TSIU, ET AL.

Plaintiff Sae Global Logistics Ltd.’s MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S SPECIAL INTERROGATORIES, SET TWO Responding Party: Non-Party, Laura Each Nguyen (i.e., former counsel for Defendant Richard Tsiu) 2. Plaintiff Sae Global Logistics Ltd.’s MOTION TO COMPEL FURTHER RESPONSES TO PLAINTIFF’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET TWO Responding Party: Non-Party, Laura Each Nguyen (i.e., former counsel for Defendant Richard Tsiu) Tentative Ruling 1. & 2. See below.

  • Hearing

    Jul 07, 2020

  • Type

    Business

  • Sub Type

    Intellectual Property

MILCAH M. FOUNTAIN VS CITY OF LOS ANGELES, ET AL.

Sanctions are mandatory in connection with a motion to compel responses to interrogatories against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel unless the court “finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.” (Code Civ. Proc., § 2030.290, subd. (c).)

  • Hearing

    Jul 06, 2020

THORESON VS. DI OVERNIGHT LLC

Motion to Compel Production. Moving Party: Plaintiff Jeffrey P. Thoreson. Responding Party: Defendants DI Overnite LLC and Philip Nabal Ruling: Plaintiff’s motion to compel is granted. If a timely motion to compel has been filed, the burden is on the responding party to justify any objection or failure to answer the interrogatories fully. (Coy v. Sup.Ct. (Wolcher) (1962) 58 Cal.2d 210, 220-221; Fairmont Ins. Co. v. Sup.Ct. (Stendell) (2000) 22 Cal.4th 245, 255.)

  • Hearing

    Jul 06, 2020

A. CHARLES WILSON VS CENTURY CITY MEDICAL PLAZA, L.P., ET AL.

Defendant’s arguments are more appropriate for a motion to compel arbitration, where the Court may adequately determine the issues before it by resort to evidence. If Defendant believes that this action should be dismissed because of Plaintiff’s failure to arbitrate, Defendant may file a motion to compel arbitration. Based on the foregoing, Defendant’s demurrer based on a failure to provide a notice of right to arbitration is OVERRULED.

  • Hearing

    Jul 06, 2020

  • Type

    Contract

  • Sub Type

    Breach

KIMBERLY CARVALHO-FAUCHER VS SERVICE CONCIERGE INC, A BUSINESS ENTITY FORM UNKNOWN, ET AL.

On March 25, 2020, Plaintiff filed a motion to compel Defendant Service Concierge, Inc. to provide verified responses without objections to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) pursuant to California Code of Civil Procedure sections 2030.290 and 2031.300. Trial is set for July 22, 2020.

  • Hearing

    Jul 06, 2020

CHRISTOPHER J MARTIN VS KARSA HEJAZI

Sanctions are mandatory in connection with a motion to compel responses to interrogatories and a request for production of documents against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel unless the court “finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.” (Code Civ. Proc., §§ 2030.290, subd. (c), 2031.300, subd. (c).)

  • Hearing

    Jul 06, 2020

RACKOW VS. DISCOVERY SCIENCE FOUNDATION

Motion to Compel Answers to Form Interrogatories OFF CALENDAR- NOTICE OF WITHDRAWAL FILED JUNE 19, 2020.

  • Hearing

    Jul 06, 2020

STEPHEN HARRIS VS JACK SWANK

Motion to Compel Responses to Supplemental Interrogatories Defendant propounded supplemental interrogatories on Plaintiff on 12/16/19. To date, despite multiple attempts to meet and confer, Plaintiff has not served responses. Defendant’s motion to compel responses is granted. CCP §2030.290. Plaintiff is ordered to serve responses to supplemental interrogatories, without objections, within ten days. IV.

  • Hearing

    Jul 06, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

MCKESSON SPECIALTY CARE DISTRIBUTION CORP. VS. LOS ALAMITOS HEMATOLOGY MEDICAL GROUP

Motion: 1) Compel Answers to Form Interrogatories 2) Compel Answers to Special Interrogatories 3) Compel Production 4) Deem Facts Admitted Moving Party: Plaintiff McKesson Specialty Care Distribution Corporation. Responding Party: None. Opposition: None Ruling: Motions 1,2,3 and 4) Plaintiff’s motion to compel is granted. Responses to interrogatories and requests for production of documents are due 30 days after service (plus appropriate time for method of service). (Code Civ. Proc. §§ 2030.260; 2031.260.)

  • Hearing

    Jul 06, 2020

JULIA NACHMAN VS CITIGROUP GLOBAL MARKETS INC., ET AL.

On February 24, 2020, the Court granted Plaintiff’s motions to compel further responses to Form Interrogatory Nos. 12.1 and 15.1; granted Plaintiff’s motion to compel further responses to Form Interrogatories – Employment Law Nos. 201.1, 201.4, 211.1, 217.1 for both Defendants Citigroup and GSCM; granted Plaintiff’s motion to compel further responses to Form Interrogatories – Employment Law No. 201.5 for Defendant Citigroup; denied Plaintiff’s motion to compel further responses to Form Interrogatories – Employment

  • Hearing

    Jul 06, 2020

  • Type

    Employment

  • Sub Type

    Wrongful Term

MOHAMAD TAVAKKOLI VS JAYENDRA A. SHAH, ET AL.

The statute contains no time limit for a motion to compel where no responses have been served. All that need be shown in the moving papers is that a set of interrogatories was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served. (Leach v. Superior Court (1980) 111 Cal. App. 3d 902, 905-906.) Where there has been no timely response to a CCP § 2031.010 demand, the demanding party must seek an order compelling a response.

  • Hearing

    Jul 02, 2020

COLOREDGE, INC., A DELAWARE CORPORATION, VS EDIE GELARDI, AN INDIVIDUAL,, ET AL.

PRESENTATION: Gelardi filed the Motion to Compel Further Responses to Special Interrogatories, Set One on March 18, 2020. Coloredge opposed the motion on June 19, 2020. Geraldi filed a notice to withdraw the motion on June 25, 2020. Gelardi filed the Motion to Compel for Order Compelling PMK on March 18, 2020, Coloredge opposed the motion on June 19, 2020, and Geraldi filed a reply on June 25, 2020.

  • Hearing

    Jul 02, 2020

  • Type

    Business

  • Sub Type

    Intellectual Property

ANDRE HARRIS, ET AL. VS ANTHONY GARCIA

Specifically, the Motion to Compel Responses to Form Interrogatories and Request for Monetary Sanctions seeks to compel responses and an award of sanctions from both Plaintiffs, who were each separately served Form Interrogatories. Similarly, the Motion to Compel Responses to Request for Production and Request for Monetary Sanctions seeks to compel responses and an award of sanctions from both Plaintiffs, who were each separately served Requests for Production.

  • Hearing

    Jul 02, 2020

DEMATTEI V. HYUNDAI MOTOR AMERICA

Sanctions are awarded against both the plaintiff and her counsel, joint and several, as follows: Motion to Compel Deposition—$698 Motion to Deem Admitted—$554 Compel Special Interrogatories—$460 Compel Form Interrogatories—$460 Compel Production—$460 Sanctions of $2,632 shall be paid by the plaintiff and her counsel to the defendant within 30 days. The defendant shall prepare the appropriate order and give notice.

  • Hearing

    Jul 02, 2020

PISANI VS VEAZY

The unopposed motion to compel responses to UHS’s special interrogatories is granted. The defendant’s request for sanctions is denied. The proposed order will be signed as modified. Analysis: Although the defendant sought sanctions in the sum of $850, no declaration explains how that sum is calculated, how many hours were incurred to bring the motion, or what hourly rate is reasonable.

  • Hearing

    Jul 02, 2020

EASY TRUCK INSURANCE SERVICES, INC. V. TEXCAZ TRANSBORDER INSURANCE INTERMEDIARIES, INC.

Motion No. 5: Defendant’s/Cross-Complainant’s (Manuel Juarez) Motion to Compel Brett Moore’s Responses to Manuel Juarez’s Special Interrogatories (Set One) (Motion), filed on 12-12-19 under ROA Nos. 157, 158, and 159, is DENIED as MOOT.

  • Hearing

    Jul 02, 2020

TAMAR SECURITIES, LLC VS TOBIE ALEXANDER RODRIGUEZ

Conclusion Based on the foregoing, Plaintiff’s motion to compel further responses to Special Interrogatories (Set One) Nos. 8, 85-91, and 94 is granted. Plaintiff’s request for sanctions is granted against Defendant and his counsel of record in the total amount of $6,435.

  • Hearing

    Jul 02, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

JOSE PICENO VS GENERAL MOTORS LLC

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

  • Hearing

    Jul 02, 2020

TERESA TORRES VS FOOD 4 LESS OF CA INC ET AL

Sanctions are mandatory in connection with a motion to compel responses to interrogatories against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel unless the court “finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust.” (Code Civ. Proc., § 2030.290, subd. (c).)

  • Hearing

    Jul 02, 2020

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