Motion to Compel Further Responses to Interrogatories in California

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 § 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 § 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 § 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 § 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 § 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 § 2030.040 permits a party to propound more than 35 special interrogatories with a declaration of necessity.

Documents for Motion to Compel Further Responses to Interrogatories in California

1-10 of 10000 results

Case Filed

Oct 15, 2019

Case Status

Active

County

San Bernardino County, CA

Filed Date

Apr 08, 2021

Type

Uninsured Motorist$10,000.01 - $25,000 Limited

Judge Hon. Jay H Robinson Trellis Spinner 👉 Discover key insights by exploring more analytics for Jay H Robinson
Case Filed

May 29, 2020

Case Status

Active

County

San Bernardino County, CA

Filed Date

Nov 07, 2022

Type

Breach of Contract/Warranty Unlimited

Judge Hon. Khymberli S Apaloo Trellis Spinner 👉 Discover key insights by exploring more analytics for Khymberli S Apaloo
Case Filed

Oct 14, 2020

Case Status

Active

County

San Bernardino County, CA

Filed Date

Apr 13, 2022

Type

Employment - Complex

Judge Hon. David Cohn Trellis Spinner 👉 Discover key insights by exploring more analytics for David Cohn
Case Filed

May 07, 2019

Case Status

Active

County

San Bernardino County, CA

Filed Date

May 03, 2021

Type

Breach of Contract/Warranty Unlimited

Judge Hon. Gilbert Ochoa Trellis Spinner 👉 Discover key insights by exploring more analytics for Gilbert Ochoa
Case Filed

Jun 17, 2019

Case Status

Active

County

San Bernardino County, CA

Filed Date

Dec 15, 2020

Type

Employment - Complex

Judge Hon. David Cohn Trellis Spinner 👉 Discover key insights by exploring more analytics for David Cohn
Case Filed

Aug 13, 2020

Case Status

Active

County

San Bernardino County, CA

Filed Date

Dec 20, 2021

Type

Employment - Complex

Judge Hon. David Cohn Trellis Spinner 👉 Discover key insights by exploring more analytics for David Cohn
Case Filed

Jun 17, 2020

Case Status

Active

County

San Bernardino County, CA

Filed Date

Oct 12, 2021

Judge Hon. Cohn, David Trellis Spinner 👉 Discover key insights by exploring more analytics for Cohn, David
Case Filed

Jun 01, 2020

Case Status

Judgment Entered

County

San Bernardino County, CA

Filed Date

Mar 29, 2021

Type

Personal Injury Motor Vehicle Unlimited

Judge Hon. Bryan Foster Trellis Spinner 👉 Discover key insights by exploring more analytics for Bryan Foster
Case Filed

Feb 06, 2020

Case Status

Active

County

San Bernardino County, CA

Filed Date

Apr 08, 2021

Type

Personal Injury Non-Motor Vehicle Unlimited

Judge Hon. John M Tomberlin Trellis Spinner 👉 Discover key insights by exploring more analytics for John M Tomberlin
Case Filed

Jul 16, 2020

Case Status

Dismissed

County

San Bernardino County, CA

Filed Date

Sep 23, 2020

Type

Uninsured Motorist Unlimited

Judge Hon. Michael A Sachs Trellis Spinner 👉 Discover key insights by exploring more analytics for Michael A Sachs

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