Defendants' evidentiary objection is sustained. A response to discovery with only objections need not be verified. Blue Ridge Ins. Co. v. sup. Ct. (Kippen) (1988) 202 Cal. App. 3d 339, 344. Therefore, Plaintiff's motion to compel further response to form interrogatories, special interrogatories, requests for production of documents and requests for admissions is timely. However, Plaintiff failed to file a separate statement pursuant to Ca. Rules of Court, Rule 3.1345, and the Court is not required to review any other document in order to determine the full request and full response. (CRC Rule 3.1345(c).) To the extent Defendants' objections are based on claims of privilege, Defendants bear the burden of establishing a factual basis for each claim so that the propounding party can evaluate the merits of each privilege claim. Lopez v. Watchtower Bible & Tract Society of New York, Inc. (2016) 246 Cal. App. 4th 566, 596. Defendants have not met their burden, and the Court grants Plaintiff'