Motion Types Legal Issues

What is a Motion to Compel Initial Responses?

“When a party to whom interrogatories are directed fails to respond, under CCP § 2030.290(b) a party propounding the interrogatories may move for an order compelling a response. A party who fails to provide a timely response waives any objection, including one based on privilege or work product.” Code Civ. Proc. § 2030.290(a).

For a motion to compel initial responses, no meet and confer is required. All that needs to be shown 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. Super. Ct. (1980) 111 Cal.App 3d 902, 905-06.

“Unlike a motion to compel further responses, a motion to compel responses is not subject to a 45–day time limit, and the propounding party does not have to demonstrate either good cause or that it satisfied a ‘meet and confer’ requirement.” Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.

Most Useful Motion to Compel Initial Responses Examples

Recent Examples of Motion to Compel Initial Responses

1-25 of 500 results

STAN KANAROWSKI V. BRUKER NANO, INC.

Nature of Proceedings: Motion Compel Requests for Admissions/Sanctions; Compel Requests for Inspection of Documents/Set One/Sanctions; Compel Responses to Interrogatories/Set One/Sanctions Tentative

  • Hearing

    Feb 24, 2020

LESLIE BLAKENEY VS SERGIO GARCIA

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) Having considered the moving and opposing papers, the Court rules as follows. No reply papers were filed. B...

...amended complaint to add a cause of action for fraud/intentional misrepresentation. On January 3, 2020, Defendants Sergio Garcia and Manuela T. Garcia filed a motion to compel Plaintiff 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 s...

  • Hearing

    Feb 20, 2020

ARSHA CORPORATION, A CALIFORNIA CORPORATION VS CEDARWOOD CAPITAL PARTNERS LA CIENGA, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY

Arsha Corp. v. Cedarwood Capital Partners La Cienega, LLC, et al. MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUESTS FOR ADMISSION, REQUESTS FOR PRODUCTION, DEPOSITION; SANCTIONS (CCP §§ 2030.290, 2031.300, 2033.380, 2025.450) TENTATIVE RULING: Plaintiff Arsha Corporation’s Motion For...

... Compelling Defendant Cedarwood Capital Partners La Cienega, LLC To Respond to Form Interrogatories, Set One and Request for Sanctions is DENIED. THE HEARING ON THE REMAINING REQUESTS IN THE MOTION TO COMPEL RESPONSES AND DEEM MATTERS ADMITTED IS CONTINUED TO APRIL 20, 2020 AT 10:30 AM IN DEPARTMENT 26. AT LEAST 16 COURT DAYS PRIOR TO THE NEW HEARING DATE, PLAINTIFF IS TO PAY THREE (3) ADDITIONAL MOTION FILING FEES...

  • Hearing

    Feb 20, 2020

CASHCALL, INC. VS LIZETT IBARRA

...call Department 20 at 408.808.6856 and the opposing party no later than 4:00 PM on 19 February 2020. Please specify the issue to be contested when calling the Court and Counsel. MOTION OF PLAINTIFF TO COMPEL DEFENDANT TO RESPOND TO FORM INTERROGATORIES (LIMITED CIVIL CASES), SET ONE; SPECIAL INTERROGATORIES, SET ONE; AND REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE I. Statement of Facts. Plaintiff filed...

...plaintiff served defendant with form interrogatories (limited civil cases), set one; special interrogatories, set one; requests for admissions, set one; and request for production of documents, set one. Responses were due on 8 November 2019. They have not been provided. The matter has a trial date of 4 May 2020. II. Analysis. Responses to interrogatories and request for production of documents are due within...

  • Hearing

    Feb 20, 2020

VERNON ALEXANDER ROSADO, ET AL. VS LQK CORPORATION

...INTERROGATORIES, AND REQUEST FOR PRODUCTION (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant LQK Corporation’s nine Motions to Compel Discovery are GRANTED. Plaintiffs are ordered to serve verified responses without objections to Defendant’s discovery requests within thirty (30) days of service of notice of this order. Defendant’s requests for monetary sanctions are also GRANTED in the reduced amount of ...

... Compel Plaintiff Alexander Protective Services’ Responses to Form Interrogatories, Set One, and Request for Monetary and Evidentiary Sanctions; (2) Motion to Compel Plaintiff Alexander Protective Services’ Responses to Special Interrogatories, Set One, and Request for Monetary and Evidentiary Sanctions; (3) Motion to Compel Plaintiff Alexander Protective Services’ Responses to Request for Production of Documents,...

  • Hearing

    Feb 19, 2020

EGAL SHAHBAZ VS SAB INVESTMENT PROPERTY, LLC, ET AL.

Shahbaz v. SAB Investment Property, LLC, et al. MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant SAB Investment Property, LLC (1) Motion For Order Compelling Plaintiff To R...

...Interrogatories; Request for Sanctions; and (2) Motion For Order Compelling Plaintiff to Respond to Request for Production of Documents; Request For Sanctions are GRANTED. PLAINTIFF TO SERVE VERIFIED RESPONSES WITHOUT OBJECTION TO THE DISCOVERY REQUESTS WITHIN 20 DAYS’ NOTICE OF THIS ORDER. THE COURT FURTHER ORDERS THAT PLAINTIFF AND COUNSEL OF RECORD ARE JOINTLY AND SEVERALLY TO PAY SANCTIONS OF $1,245.00 ...

  • Hearing

    Feb 19, 2020

JOSE FLORES VS TONYA RAVEN

MOTION TO DEEM REQUESTS FOR ADMISSION ADMITTED; MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES AND COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (CCP §§ 2030.290; 2031.300; 2033.280) TENTATIVE RULING: Defendant Tonya Raven’s (1) Motion for Order that the Truth of Any Matters Specified in Requests for Admission be ...

...Admitted, (2) Motion to Compel Discovery Responses to Demand for Production of Documents, and (3) Motion to Compel Discovery Responses to Form Interrogatories are GRANTED. Plaintiff is ordered to serve responses without objections to Form Interrogatories and Request for Production of Documents within thirty (30) days of service of notice of this order. Defendant’s requests for sanctions are also GRANTED in t...

  • Hearing

    Feb 18, 2020

TAKOUHI KAIMATLIAN VS 99 CENTS ONLY STORES

Motion to Compel Responses to Supplemental Interrogatories, Supplemental Special Interrogatories, and Supplemental Request for Production (All Set Two) Having considered the moving, opposing, and reply papers, the Court rules ...

...(“Defendant”). The complaint alleges premises liability and negligence for a trip-and-fall that occurred on October 27, 2014. On January 21, 2020, Defendant filed motions to compel Plaintiff to provide verified responses without objections to Supplemental Interrogatories, Supplemental Special Interrogatories, and Supplemental Request for Production (All Set Two) pursuant to California Code of Civil Procedure sections ...

  • Hearing

    Feb 18, 2020

KRISTEN ASKEW VS ON TIME OIL, LLC, ET AL.

...Plaintiff Kristen Askew’s motions to compel responses to form interrogatories (general and employment law), special interrogatories, and production of documents are GRANTED. Defendant is ordered to provide responses within 20 days. Plaintiff Kristen Askew (“Plaintiff”), moves the court for orders requiring Defendant On Time Oil, LLC (“Defendant”) to provide verified responses to its form interrogatories – genera...

...responding party waives objections. (CCP § 2030.290(a).) CCP § 2031.300(b) allows the propounding party to file a motion to compel responses to produce documents if a response has not been received. If responses are untimely, responding party waives objections. (CCP § 2031.300(a).) Where verification is required by the discovery statute, an unverified response is ineffective and is equivalent to no response a...

  • Hearing

    Feb 18, 2020

EGAL SHAHBAZ VS SAB INVESTMENT PROPERTY, LLC, ET AL.

Shahbaz v. SAB Investment Property, LLC, et al. MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant SAB Investment Property, LLC (1) Motion For Order Compelling Plaintiff To R...

...Interrogatories; Request for Sanctions; and (2) Motion For Order Compelling Plaintiff to Respond to Request for Production of Documents; Request For Sanctions are GRANTED. PLAINTIFF TO SERVE VERIFIED RESPONSES WITHOUT OBJECTION TO THE DISCOVERY REQUESTS WITHIN 20 DAYS’ NOTICE OF THIS ORDER. THE COURT FURTHER ORDERS THAT PLAINTIFF AND COUNSEL OF RECORD ARE JOINTLY AND SEVERALLY TO PAY SANCTIONS OF $1,245.00 ...

  • Hearing

    Feb 18, 2020

GARCIA V. ACTERBERG

Defendant’s Motion to Compel Responses to Interrogatories and Requests for Production. Defendant’s counsel declares: on October 29, 2019 form and special interrogatories and requests for production were served on plaintiff; and despite a r...

...to plaintiff’s address of record on January 13, 2020. There is no opposition to the motion in the court’s file. The party to whom interrogatories and requests for production have been served must serve responses upon the propounding party within 30 days after service or any other later date the propounding party stipulates to. (Code of Civil Procedure, §§ 2030.260, 2030.270, 2031.260, and 2031.270.) The failu...

  • Hearing

    Feb 14, 2020

MANUEL MARTINEZ VS MICHAEL DOKUNMU

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) Having considered the moving papers, the Court rules as follows. No opposing papers were filed. BACKGROUND ...

...(“Defendant”) alleging negligence and negligence per se for an automobile collision that occurred on April 25, 2016. On December 6, 2019, Defendant filed motions to compel Plaintiff 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 s...

  • Hearing

    Feb 13, 2020

NATASHA TORRES, ET AL. VS VICKY KHONG

...Khong, et al. MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant Vicky Khong’s (1) Motion For Order Compelling Plaintiff Natasha Torres To Respond to Form Interrogatories; Request for Sanctions; (2) Motion For Order Compelling Plaintiff Natasha Torres To Respond to Special Interrogatories; Request for Sanc...

...for Sanctions; and (6) Motion For Order Compelling Plaintiff David Mujica to Respond to Request for Production of Documents; Request For Sanctions are GRANTED. PLAINTIFFS ARE ORDERED TO SERVE VERIFIED RESPONSES WITHOUT OBJECTIONS TO THE INTERROGATORIES AND REQUESTS FOR PRODUCTION WITHIN 20 DAYS’ NOTICE OF THIS ORDER. THE REQUEST FOR SANCTIONS IS ALSO GRANTED AGAINST EACH PLAINTIFF IN THE AMOUNT OF $310.00. S...

  • Hearing

    Feb 13, 2020

NATASHA TORRES, ET AL. VS VICKY KHONG

...Khong, et al. MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant Vicky Khong’s (1) Motion For Order Compelling Plaintiff Natasha Torres To Respond to Form Interrogatories; Request for Sanctions; (2) Motion For Order Compelling Plaintiff Natasha Torres To Respond to Special Interrogatories; Request for Sanc...

...for Sanctions; and (6) Motion For Order Compelling Plaintiff David Mujica to Respond to Request for Production of Documents; Request For Sanctions are GRANTED. PLAINTIFFS ARE ORDERED TO SERVE VERIFIED RESPONSES WITHOUT OBJECTIONS TO THE INTERROGATORIES AND REQUESTS FOR PRODUCTION WITHIN 20 DAYS’ NOTICE OF THIS ORDER. THE REQUEST FOR SANCTIONS IS ALSO GRANTED AGAINST EACH PLAINTIFF IN THE AMOUNT OF $310.00. S...

  • Hearing

    Feb 13, 2020

DELTA RIDGE HOMEOWNERS ASSOCIATION. VS MIGUEL A ARZATE

MOTION TO DEEM REQUESTS FOR ADMISSION ADMITTED; MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES AND COMPEL RESPONSES TO REQUESTS FOR PRODUCTION (CCP §§ 2030.290; 2031.300; 2033.280) TENTATIVE RULING: Plaintiff Delta Ridge Homeowners Association’s (1...

...Association’s (1) Motion to Deem Requests for Admissions, Set One, Admitted, (2) Motion to Compel Defendant to Provide Responses to Form Interrogatories, Set one, and (3) Motion to Compel Defendant to Provide Responses to Demand for Production of Documents, Set One, are GRANTED. Plaintiff’s request for sanctions is also GRANTED in the amount of $930.00 to be paid within thirty (30) days of service of notice of this...

  • Hearing

    Feb 10, 2020

SAM ROTER VS VALEE KUNARGTHAI

...2020. A reply brief to the motion to compel further was filed on January 31, 2020. RELIEF REQUESTED: Defendant moves to compel Plaintiff’s responses to Form Interrogatories, Set One. Defendant moves to compel Plaintiff’s further responses to Special Interrogatories, Set Two. DISCUSSION: Standard of Review – Compel Interrogatories – A motion to compel responses to interrogatories may be brought where a re...

...the instant motion to compel responses to Form Interrogatories, Set One. As Defendant requests that no sanctions be imposed for Plaintiff’s failure to respond, the Court will not impose sanctions. --- Compel Further Responses to Interrogatories – Code of Civil Procedure §2030.300 provides for a party to bring a motion to compel further responses to interrogatories where the responding party provides inade...

  • Hearing

    Feb 7, 2020

MARTHA ESTERLINE VS JEFFREY C CHONG ET AL

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) Having considered the moving papers, the Court rules as follows. No opposing papers were filed. BACKGROUND ...

...medical malpractice for a failure to diagnose cancer between April 2011 and September 2016. On January 6, 2020, Defendant Jeffrey C. Chong, M.D. filed motions to compel Plaintiff 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 s...

  • Hearing

    Feb 7, 2020

CLADY WILLIAMS VS ALICIA SEVILLA

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One); Motion to Deem Matters in Request for Admissions (Set One) as True; Motion to Compel Deposition Having cons...

...complaint alleges motor vehicle and general negligence for an automobile collision that occurred on September 29, 2016. On December 31, 2019, Defendant filed motions to compel Plaintiff 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. Also on Dec...

  • Hearing

    Feb 7, 2020

KATHY BUKSZAR, ET AL. VS BONG KANG, AND INDIVIDUAL AND DBA PACIFIC PAINTING CO., ET AL.

...OF DOCUMENTS AND REQUEST FOR SANCTIONS (CCP §§ 2030.290, 2031.300) TENTATIVE RULING: Defendants Bong Kang and Pacific Paint and Construction, Inc.’s Motions to Compel Discovery are GRANTED. Verified responses without objections to the Form Interrogatories and Requests for Production of Documents separately propounded to Speros Maniates and Kathy Bukszar are to be served within 30 days of service of this or...

...Construction, Inc. (collectively, “Defendants”). On October 7, 2019, Defendants filed an Answer. On January 2, 2020, Defendants filed the following four motions (1) Motion to Compel Plaintiff Speros Maniates’ Responses to Request for Production of Documents, Set One, and Request for Sanctions; (2) Motion to Compel Plaintiff Kathy Bukszar’s Responses to Request for Production of Documents, Set One, and Request for Sa...

  • Hearing

    Feb 6, 2020

KATHY BUKSZAR, ET AL. VS BONG KANG, AND INDIVIDUAL AND DBA PACIFIC PAINTING CO., ET AL.

...OF DOCUMENTS AND REQUEST FOR SANCTIONS (CCP §§ 2030.290, 2031.300) TENTATIVE RULING: Defendants Bong Kang and Pacific Paint and Construction, Inc.’s Motions to Compel Discovery are GRANTED. Verified responses without objections to the Form Interrogatories and Requests for Production of Documents separately propounded to Speros Maniates and Kathy Bukszar are to be served within 30 days of service of this or...

...Construction, Inc. (collectively, “Defendants”). On October 7, 2019, Defendants filed an Answer. On January 2, 2020, Defendants filed the following four motions (1) Motion to Compel Plaintiff Speros Maniates’ Responses to Request for Production of Documents, Set One, and Request for Sanctions; (2) Motion to Compel Plaintiff Kathy Bukszar’s Responses to Request for Production of Documents, Set One, and Request for Sa...

  • Hearing

    Feb 6, 2020

GYE DONG JUNG VS BRANDEN J MARTINEZ

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set One) Having considered the moving papers, the Court rules as follows. No opposing papers were filed. BACKGROUND ...

...Branden J. Martinez (“Defendant”) alleging motor vehicle negligence for an incident that occurred on November 9, 2017. On December 20, 2020, Defendant filed motions to compel Plaintiff 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 s...

  • Hearing

    Feb 6, 2020

MARLIES HAGEN VS MICHAEL MILLER

Motion to Compel Responses to Supplemental Interrogatories and Request for Production Having considered the moving, opposing, and reply papers, the Court rules as follows. BACKGROUND On July 26, 2018, Plaintiff Marlies Hagen...

...The complaint alleges a violation of California Civil Code section 3342 and negligence for a dog bite that occurred on September 23, 2016. January 7, 2020, Defendant filed motions to compel Plaintiff’s responses to Supplemental Interrogatories and Request for Production pursuant to California Code of Civil Procedure sections 2030.290 and 2031.300. Trial is set for July 23, 2020. PARTY’S REQUESTS Defendant ...

  • Hearing

    Feb 6, 2020

JANICE KROK VS CITY OF WEST HOLLYWOOD

...v. City of West Hollywood, et al., BS172553 Tentative decision on motion to compel compliance with court order: granted without sanctions Respondent City of West Hollywood (“City”) moves for an order compelling Petitioner Janice Krok (“Krok”) to comply with the court’s May 28, 2019 order and provide responses without objection to the City's General Form Interrogatories (Set One), Special Interrogatories ...

...excessive fine, in violation of the United States and California constitutions, has damaged Krok in an amount to be proven. 2. Course of Proceedings On May 28, 2019, the court granted the City’s motion to compel responses to interrogatories and request for production, giving Krok 30 days to respond. The court denied the City’s motion for an order deeming its request for admission admitted because responses ha...

  • Hearing

    Feb 6, 2020

IN RE THE THOMPSON FAMILY TRUST

...interrogatories (Ex. A), form interrogatories (Ex. B), requests for admission (Ex. C), and requests for production of documents (Ex. D), on Objector. Now before the Court is Petitioner’s motion for an order compelling Objector to respond to the interrogatories, form interrogatories, requests for admission (RFAs), and requests for production of documents (RFPs). Petitioner also requests that the genuineness of t...

...equivalent to no response at all, and therefore are not in “substantial compliance” with Section 2033.240(a). (Allen-Pacific, Ltd., supra, 57 Cal.App.4th at p. 1551.) “[W]oe betide the party who fails to serve responses before the hearing. In that instance the court has no discretion but to grant the admission motion, usually with fatal consequences for the defaulting party. One might call it ‘two strikes and you’re ...

  • Hearing

    Feb 5, 2020

GENARO CAPETILLO VS JENNIFER WHEELESS

Motion to Compel Responses to Form Interrogatories, Special Interrogatories, and Request for Production (All Set Two); Motion to Deem Matters in Request for Admissions (Set One) as True Having considered the moving, opposing, ...

...(“Defendant”) alleging motor vehicle and general negligence for an automobile collision that occurred on July 6, 2016. On January 8, 2020, Defendant filed motions to compel Plaintiff to provide verified responses without objections to Form Interrogatories, Special Interrogatories, and Request for Production (All Set Two) pursuant to California Code of Civil Procedure sections 2030.290 and 2031.300. Also on Ja...

  • Hearing

    Feb 5, 2020

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