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

WILSON & PETTINE LLP V. TIMOTHY DELANEY

The Motion to Compel Filed 8/28/20; the motion itself comprised 518 pages, but the text of the motion is about four pages; the attorney fee declaration is about five pages; attached are Exhibits A through I that are the underlying discovery documents, letters emails referenced in the motion. Plaintiff gave several time extensions and ran out of patience; no responses had been served when the motion was filed. Seeks: 1.

  • Hearing

    Sep 22, 2020

OTILIA MEZA VS MICHELLE FRANCO, ET AL.

The court awards Defendant one hour for preparing each form motion to compel and one hour for appearing at the hearing- but awards this time only once- all at the requested rate of $143.75, for a total attorney’s fees award of $575. 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. Further, Defendant is awarded the $60 motion filing fee for each of the three motions for a total of $195 in costs.

  • Hearing

    Sep 22, 2020

(NO CASE NAME AVAILABLE)

The Motion to Compel Responses With respect to the motion to compel responses, the Court GRANTS Plaintiff’s request for sanctions and awards Plaintiff a reasonable amount of sanctions of $600.00 in connection with his motion to compel responses. (Doppes v. Bentley Motors, Inc. (2009) 174 Cal.App.4th 967, 992.) Sanctions are to be paid to Plaintiff by GSP within 20 days of the date of this order in connection with the motion.

  • Hearing

    Sep 22, 2020

TAULER SMITH LLP VS JOSEPH VALERIO, ET AL.

On June 3, 2020, Plaintiff filed the instant Motion to Compel Further Responses to Requests for Admission, Requests for Production of Documents, Form Interrogatories and Special Interrogatories; Request for Sanctions. On August 31, 2020, the Court denied the Motion to Reclassify. Defendants filed an opposition to the Motion to Compel Further on September 8, 2020.

  • Hearing

    Sep 22, 2020

  • County

    Los Angeles County, CA

(NO CASE NAME AVAILABLE)

.: 18SMCV00212 Hearing Date: September 21, 2020 [TENTATIVE] order RE: MOTION TO compel responses to Defendants’: (1) form interrogatories, SET TWO (2) Sanctions BACKGROUND On November 9, 2018, Plaintiffs Hero Dogs Season One LLC (“Hero Dogs”) and Nuriya Entertainment LLC (“Nuriya”) (collectively, “Plaintiffs”) filed the original complaint against Defendants Dean A.

  • Hearing

    Sep 21, 2020

HAMVAY V. KNOLLS WEST POST ACUTE, LLC

Motion to Compel Answers to Special Interrogatories OFF CALENDAR – Telephone withdrawal by moving party

  • Hearing

    Sep 21, 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.

Moreover, Defendants did not file separate statements specifically addressing the requests and interrogatories at issue and Akinyemi did not file an opposition as to the motion to compel further responses to Form Interrogatories.

  • 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

SANTOS SALVATIERRA, ET AL. VS JOSEPH P MARSICO

Accordingly, if not mooted prior to the hearing, the motion to compel Plaintiff Santos Salvatierra’s responses to special interrogatories (set one) is GRANTED. Plaintiff is to provide verified responses, without objection, within 30 days of the date of this Order. Motion to Compel Answers to Special Interrogatories: Stephanie Salvatierra The relevant law and facts are identical as to the special interrogatories served on Stephanie Salvatierra.

  • 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

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

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

BRET BOCCHIERI VS FARMERS INSURANCE

Responses to the form interrogatories, without objection, must be served within ten (10) days of today’s date. If a motion to compel response is filed, the court “shall” impose a monetary sanction against the losing party unless it finds that party made or opposed the motion “with substantial justification” or other reasons make the sanction “unjust.” (Code Civ. Proc., § 2031.300, subd. (c).)

  • Hearing

    Sep 21, 2020

  • Type

    Insurance

  • Sub Type

    Intellectual Property

PIAZZA V. THE IRVINE COMPANY APARTMENT COMMUNITIES, INC.

Motion to Compel Answers to Form Interrogatories 2. Motion to Compel Answers to Form Interrogatories 3. 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

KIMBERLY BOUSSARD VS CHARLES SHORTER

The court awards one hour for preparing each form motion to compel and one hour for appearing at the hearing- but awards this time only once- all at the requested rate of $175 per hour, for a total attorneys’ fees award of $1,750. The court also awards nine motion filing fees of $60 each, or $540 in costs. Defendant seeks sanctions against Plaintiffs and Plaintiff’s attorney of record; however, Defendant does not describe any conduct warranting sanctions against Plaintiffs personally.

  • Hearing

    Sep 21, 2020

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

If a timely motion to compel a further response to an interrogatory has been filed, the burden is on the responding party to justify any objection or failure fully to answer the interrogatories. (Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.) Laura seeks further responses to SROG Nos. 4-8 and 10. Steven seeks further responses to SROG Nos. 4-7, 11-14, 25-29, and 31. A.

  • Hearing

    Sep 21, 2020

  • Type

    Employment

  • Sub Type

    Other Employment

MARCIA GENELL RICHARDSON VS. CHIPOTLE MEXICAN GRILL

Motion #2: The court intends to grant defendant's Motion to Compel Responses to Supplemental Request for Production of Documents by no later than October 9, 2020, without objection. Motion #3: The court intends to grant defendant's Motion to Compel Responses to Supplemental Interrogatories by no later than October 9, 2020, without objection..

  • Hearing

    Sep 18, 2020

ABRAHAMS VS. HAMPTON

HEARING ON MOTION TO COMPEL DISCOVERY RESPONSES FROM DEFENDANT FILED BY HARRY ABRAHAMS * TENTATIVE RULING: * Plaintiff’s motion to compel discovery responses from defendant Hampton, and to deem matters admitted, is granted in part. The motion is denied insofar as it requests that matters be deemed admitted. Hampton has served responses to the requests for admission before the hearing date of the motion. As for the other discovery, however, the motion is granted.

  • Hearing

    Sep 18, 2020

DARSHAN THIND VS MUKHTIAR S KAMBOJ ET AL

Responses to Requests for Admission, Set 1; (6) Motion to Compel Amadeep Kamboj’s Amended Responses to Form Interrogatories, Set 1; (7) Motion to Compel Amadeep Kamboj’s Amended Responses to Special Interrogatories, Set 1; (8) Motion to Compel Amadeep Kamboj’s Amended Responses to Requests for Production of Documents, Set 1; (9) Motion to Compel Los Angeles Central Property’s Amended Responses to Form Interrogatories, Set 1; (10) Motion to Compel Los Angeles Central Property’s Amended Responses to Special Interrogatories

  • Hearing

    Sep 18, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

INTERINSURANCE EXCHANGE OF THE AUTOMOBILE CLUB VS. HILL

Motion to Compel Answers to Form Interrogatories 2. Motion to Compel Answers to Form Interrogatories 3. 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

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

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

BASITTA MINTER VS JOYCE HARLAN

CASE NO: 18STCV08789 [TENTATIVE] ORDER GRANTING MOTION TO COMPEL RESPONSES AND MOTION TO DEEM REQUESTS FOR ADMISSION ADMITTED Dept. 31 1:30 p.m. September 18, 2020 Defendant, Joyce Harlan propounded form interrogatories, set one, special interrogatories, set one, RPDs, set one, and RFAs, set one, on Plaintiff on 3/13/20. To date, despite attempting to meet and confer, Plaintiff has not served responses.

  • Hearing

    Sep 18, 2020

JACOBS V. MARION, ET AL.

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. Superior Court (2000) 22 Cal.4th 245, 255.) Each answer in the response must be “as complete and straightforward as the information reasonably available to the responding party permits. If an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Code Civ. Proc., § 2030.220, subds. (a), (b).)

  • Hearing

    Sep 18, 2020

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