Defendant has failed to submit declarations to support the burden objection to the request for production of documents. (West Pico Furniture Co v Superior Court (1961) 56 Cal.2d 407, 417 [The objection based upon burden must be sustained by evidence showing  the quantum of work required, while to support an objection of oppression there must be some showing either of an intent to create an unreasonable burden or that the ultimate effect of the burden is incommensurate with the result  sought] ; Mead Reinsurance Co. v Superior Court (1986) 188 Cal.App.3d 313, 321.) Defendant has not asserted a privilege based on commercial confidentiality. (Code Civ. Prov. §2031.240 ( b)(2 and ( c)(1).) Accordingly, plaintiff’s motion to compel a further response to the request for documents is granted. Further verified responses are due 15 days from service of notice of ruling. Sanctions are ordered in the sum of $3960. A document production date will be set at the hearing.