Plaintiff Guadalupe Rodriguez' Motion To Compel Further Responses To Form Interrogatories

This motion was timely served and filed on November 18, 2019, which is prior to the November 19, 2019 deadline based upon Defendant’s mail service of responses on September 30, 2019.

Plaintiff’s counsel engaged in sufficient meet and confer efforts prior to bringing this motion. See Declaration of Daniel J. Friedman, ¶ 6; Exh. 5.

Form Interrogatories—Employment Law Nos. 200.1, 200.2, 200.3, 200.4, 200.5, 200.6, 201.1, 201.2, 201.3, 201.4, 201.5, 201.6, 201.7, 206.2, 206.3, 207.1, 207.2, 208.1, 208.2, 209.2, 211.1, 211.2, 211.3, 214.1, 214.2, 215.1, 215.2, 216.1, 217.1: GRANT.

The responses do not comply with CCP § 2030.220, which states:

(a) Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the responding party permits.

(b) If an interrogatory cannot be answered completely, it shall be answered to the extent possi