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.

Useful Rulings on Motion to Compel Initial Responses

Recent Rulings on Motion to Compel Initial Responses

CICINDELAE, INC., ET AL. VS SHERRIE CARR, ET AL.

., para. 5) Date Responses served: NO RESPONSES SERVED Date Motion served: June 30, 2020 Timely OPPOSITION: No opposition ANALYSIS: Procedural Plaintiff has filed four motions, each of which seek to compel responses to interrogatories, and for an order deeming RFAs admitted. Two of the four also seek responses to requests for production of documents. Each of the four motions is accordingly two or three motions, lumped into one motion.

  • Hearing

    Sep 18, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

VERNON ROSADO, ET AL. VS REBECCA ABBOTT, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP § 2030.290, 2031.290) TENTATIVE RULING: DEFENDANT REBECCA ABBOTT’S MOTIONS TO COMPEL PLAINTIFFS’ VERIFIED RESPONSES TO FORM INTERROGATORIES, SPECIAL INTERROGATORIES, AND REQUEST FOR PRODUCTION OF DOCUMENTS, AND REQUESTS FOR MONETARY SANCTIONS ARE DENIED.

  • Hearing

    Sep 17, 2020

  • County

    Los Angeles County, CA

RICKY HINTON VS NORMA PROCTOR

MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND REQUEST FOR PRODUCTION (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant Norma Proctor’s Motion to Compel Discovery Responses is GRANTED. PLAINTIFF RICKY HINTON IS TO SERVE VERIFIED RESPONSES WITHOUT OBJECTION TO THE SPECIAL INTERROGATORIES, SET ONE AND REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE, WITHIN 20 DAYS OF SERVICE OF THIS ORDER.

  • Hearing

    Sep 17, 2020

  • County

    Los Angeles County, CA

TCF CO. LLC, A NEVADA LIMITED LIABILITY COMPANY VS RIVO USA CO. LTD., A NEVADA DOMESTIC CORPORATION

Motion To Deem RFAs Admitted/Compel Responses To Interrogatories and Requests For Production of Documents Plaintiff TCF Co., LLC moves to deem admitted the truth of the matters asserted in requests for admission, to compel responses to form and special interrogatories and requests for production of documents, for document production, and for sanctions.

  • Hearing

    Sep 17, 2020

RICKY HINTON VS NORMA PROCTOR

MOTION TO COMPEL RESPONSES TO INTERROGATORIES AND REQUEST FOR PRODUCTION (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Plaintiff Ricky Hinton’s Motion to Compel Discovery Responses is GRANTED. DEFENDANT NORMA PROCTOR IS TO SERVE VERIFIED RESPONSES WITHOUT OBJECTION TO THE SPECIAL INTERROGATORIES, SET ONE AND REQUESTS FOR PRODUCTION OF DOCUMENTS, SET ONE, WITHIN 20 DAYS OF SERVICE OF THIS ORDER.

  • Hearing

    Sep 17, 2020

  • County

    Los Angeles County, CA

SIMEON THOMPSON VS FELTON BUCKHOLTZ, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Plaintiff Simeon Thompson’s Motion For Order Compelling Defendants to Respond to Form Interrogatories and Request for Production of Documents; Request For Sanctions is GRANTED. DEFENDANTS ARE TO SERVE VERIFIED RESPONSES WITHOUT OBJECTION TO THE DEMANDS FOR INSPECTION AND FORM INTERROGATORIES WITHIN 20 DAYS OF SERVICE OF THIS ORDER.

  • Hearing

    Sep 16, 2020

  • County

    Los Angeles County, CA

(NO CASE NAME AVAILABLE)

MOTION TO COMPEL RESPONSES TO INTERROGATORIES, REQUEST FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP §§ 2030.290; 2031.300) TENTATIVE RULING: Defendant Magic Mountain, LLC’s (1) Motion For Order Compelling Plaintiff To Respond to Supplemental Interrogatories; Request for Sanctions; and (2) Motion For Order Compelling Plaintiff to Respond to Supplemental Request for Production of Documents; Request For Sanctions are GRANTED.

  • Hearing

    Sep 16, 2020

  • County

    Los Angeles County, CA

DAMECIA STINGLEY VS MARVIN ALPERIN, ET AL.

September 15, 2020 Defendants’ motion to compel responses to interrogatories and RPDs was originally set for hearing on 4/1/20. Based on current conditions, including, but not limited to, the spread of Covid-19, the court set these matters to be heard on 9/15/20 and ordered the moving party, Defendants, to give notice of the hearing date. (Minute Order 4/27/20.) As of 9/9/20, moving Defendants have not filed any such notice with this court.

  • Hearing

    Sep 15, 2020

TERESA SCOTT SANCHEZ, ET AL. VS STEPHEN PETER SCHIMKOS

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP § 2030.290, 2031.290) TENTATIVE RULING: DEFENDANT STEPHEN PETER SCHIMKUS’ MOTION TO COMPEL PLAINTIFFS’ VERIFIED RESPONSES TO FORM INTERROGATORIES, SET ONE AND REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; AND REQUEST FOR MONETARY SANCTIONS IS DENIED.

  • Hearing

    Sep 14, 2020

  • County

    Los Angeles County, CA

CA HOME BUYERS 247, LLC. VS HOWARD EDWARD TERRELL, JR.

September 11, 2020 Defendants’ motions to compel responses to interrogatories and RPDs was originally set for hearing on 4/3/20. Based on current conditions, including, but not limited to, the spread of Covid-19, the court set these matters to be heard on 9/11/20 and ordered the moving party, Defendants, to give notice of the hearing date. (Minute Order 4/24/20.) As of 9/3//20, moving Defendant has not filed any such notice with this court.

  • Hearing

    Sep 11, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    Fraud

RICHARD JETER, JR., ET AL. VS MARCOS RIVAS

There is no time limit for a motion to compel responses to interrogatories other than the cut-off on hearing discovery motions 15 days before trial. (Code Civ. Proc., §§ 2024.020, subd. (a), 2030.290.) No meet and confer efforts are required before filing a motion to compel responses to the discovery. (Code Civ. Proc., § 2030.290; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.)

  • Hearing

    Sep 09, 2020

  • Judge

    James E. Blancarte

  • County

    Los Angeles County, CA

JOSE M. GALLARDO VS. MARIA LUZ ELENA CHRISTOPHER

CCP § 2030.290(b) allows the propounding party to file a motion to compel responses to interrogatories if a response has not been received. If responses are untimely, responding party waives objections. (CCP § 2030.290(a).)

  • Hearing

    Sep 09, 2020

  • Type

    Real Property

  • Sub Type

    Quiet Title

  • Judge

    Lori Ann Fournier or Olivia Rosales

  • County

    Los Angeles County, CA

(NO CASE NAME AVAILABLE)

There is no time limit for a motion to compel responses to interrogatories other than the cut-off on hearing discovery motions 15 days before trial. (Code Civ. Proc., §§ 2024.020, subd. (a), 2030.290.) No meet and confer efforts are required before filing a motion to compel responses to the discovery. (Code Civ. Proc., § 2030.290; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 411.)

  • Hearing

    Sep 09, 2020

  • Judge

    James E. Blancarte

  • County

    Los Angeles County, CA

HARCO NATIONAL INSURANCE COMPANY, A CORPORATION VS AMBER NAGLE, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; DEEM REQUESTS FOR ADMISSION ADMITTED (CCP §§ 2030.290; 2033.280) TENTATIVE RULING: Plaintiff Harco National Insurance Company’s (1) Motion to Compel Responses to Form Interrogatories, Set One and Request for Sanctions; and (2) Motion to Deem the Truth of Matters in Request for Admissions as Admitted and Request for Sanctions are GRANTED. RESPONSES TO THE INTERROGATORIES ARE TO BE SERVED BY DEFENDANT DAPHNE EVANGELISTA WITHIN 20 DAYS’ SERVICE OF THIS ORDER.

  • Hearing

    Sep 03, 2020

  • County

    Los Angeles County, CA

HANNELORE CISNEROS VS TRACT 349, MUTUAL WATER COMPANY

Sanctions are mandatory in connection with motions to compel responses to interrogatories and requests for production of documents against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel. (CCP §§ 2030.290(c) and 2031.300(c).) However, sanctions are not mandatory if 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.” (Ibid.)

  • Hearing

    Sep 03, 2020

  • Type

    Personal Injury/ Tort

  • Sub Type

    other

  • Judge

    Lori Ann Fournier or Olivia Rosales

  • County

    Los Angeles County, CA

MARITZA CUEVAS VS VICTOR HUGO BELTRAN, ET AL.

Sanctions are mandatory in connection with motions to compel responses to interrogatories and requests for production of documents against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel. (Code Civ. Proc., §§ 2030.290, subd. (c) and 2031.300, subd. (c).) However, sanctions are not mandatory if 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.” (Ibid.)

  • Hearing

    Sep 03, 2020

RODOLFO A. PINEDA, ET AL. VS JOANNA OTERO

There is no time limit for a motion to compel responses to interrogatories or production of documents other than the cut-off on hearing discovery motions 15 days before trial. (Code Civ. Proc., §§ 2024.020, subd. (a), 2030.290; Code Civ. Proc., § 2031.300.) No meet and confer efforts are required before filing a motion to compel responses to the discovery. (Code Civ. Proc., § 2030.290; Code Civ. Proc., § 2031.300; Sinaiko Healthcare Consulting, Inc. v.

  • Hearing

    Sep 03, 2020

  • Judge

    James E. Blancarte

  • County

    Los Angeles County, CA

TRI-CHEM TECHNOLOGY CORP. VS SOUTHWEST MECHANICAL, INC, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP § 2030.290, 2031.290) TENTATIVE RULING: PLAINTIFF TRI-CHEM TECHNOLOGY, CORPORATION’S (1) MOTION TO COMPEL DEFENDANTS’ RESPONSES TO FIRST SET OF INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS; AND (2) MOTION TO COMPEL DEFENDANTS’ RESPONSES TO FIRST SET OF DEMAND FOR PRODUCTION; REQUEST FOR MONETARY SANCTIONS IS DENIED.

  • Hearing

    Sep 02, 2020

  • County

    Los Angeles County, CA

TRI-CHEM TECHNOLOGY CORP. VS SOUTHWEST MECHANICAL, INC, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; REQUESTS FOR PRODUCTION; REQUEST FOR SANCTIONS (CCP § 2030.290, 2031.290) TENTATIVE RULING: PLAINTIFF TRI-CHEM TECHNOLOGY, CORPORATION’S (1) MOTION TO COMPEL DEFENDANTS’ RESPONSES TO FIRST SET OF INTERROGATORIES; REQUEST FOR MONETARY SANCTIONS; AND (2) MOTION TO COMPEL DEFENDANTS’ RESPONSES TO FIRST SET OF DEMAND FOR PRODUCTION; REQUEST FOR MONETARY SANCTIONS IS DENIED.

  • Hearing

    Sep 02, 2020

WESTLAKE SERVICE, LLC VS ASMA S LLC, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; (CCP § 2030.290) TENTATIVE RULING: Plaintiff Westlake Service, LLC’s Motion To Compel Responses To Form Interrogatories, Special Interrogatories, Request For Admission, And Demand For Production Of Documents; Request For Monetary Sanctions is PLACED OFF CALENDAR IN LIGHT OF DEFENDANT FAIZULLAH SHAIKH BEING IN DEFAULT. ANALYSIS: On March 8, 2018, Plaintiff Westlake Services, Inc.

  • Hearing

    Sep 01, 2020

DINORAH ECHAVARRIA VS BOB PSZYK, ET AL.

CCP §§ 2030.290(b) and 2031.300(b) allow the propounding party to file a motion to compel responses to interrogatories and document demands if a response has not been received. If responses are untimely, responding party waives objections. (CCP §§ 2030.290(a) and 2031.300(a).) Plaintiff served belated responses that interposed objections even though she had waived objections. Further, Plaintiff failed to serve any responses in her capacity as an individual. Accordingly, the motions are GRANTED.

  • Hearing

    Sep 01, 2020

  • Judge

    Lori Ann Fournier or Olivia Rosales

  • County

    Los Angeles County, CA

WESTLAKE SERVICE, LLC VS ASMA S LLC, ET AL.

MOTION TO COMPEL RESPONSES TO INTERROGATORIES; (CCP § 2030.290) TENTATIVE RULING: Plaintiff Westlake Service, LLC’s Motion To Compel Responses To Form Interrogatories, Special Interrogatories, Request For Admission, And Demand For Production Of Documents; Request For Monetary Sanctions is PLACED OFF CALENDAR IN LIGHT OF DEFENDANT FAIZULLAH SHAIKH BEING IN DEFAULT. ANALYSIS: On March 8, 2018, Plaintiff Westlake Services, Inc.

  • Hearing

    Sep 01, 2020

  • County

    Los Angeles County, CA

MARIA WILMINDA-SICO, ET AL. VS VICTORIA DO LEE

Sanctions are mandatory in connection with motions to compel responses to interrogatories and requests for production of documents against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel. (CCP §§ 2030.290(c), 2031.300(c).) However, sanctions are not mandatory if 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.” (Id.)

  • Hearing

    Aug 31, 2020

ADRINE MOUSAKHANIAN VS UNITED VALET PARKING, ET AL.

Sanctions are mandatory in connection with motions to compel responses to interrogatories and requests for production of documents against any party, person, or attorney who unsuccessfully makes or opposes a motion to compel. (CCP §§ 2030.290(c), 2031.300(c).) However, sanctions are not mandatory if 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.” (Id.)

  • Hearing

    Aug 31, 2020

VELASQUEZ VS. ANAHEIM TERRACE CARE CENTER, LLC

If “good cause” is shown by the moving party, the burden is then on the responding party to justify any objections made to document disclosure—the same as on motions to compel responses to interrogatories or deposition questions. (Kirkland v. Super. Ct. (2002) 95 Cal.App.4th 92, 98.) Plaintiffs show good cause for the production of responsive documents for a limited scope only, from June 2017 and June 2018 only. (See Siegel Decl. ¶¶ 10-11.)

  • Hearing

    Aug 28, 2020

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