Defendant’s (Manor Care of Fountain Valley CA, LLC) Motion for Relief from Potential Waiver of Discovery Objections (Motion), filed on 7-24-19, is GRANTED.
Code of Civil Procedure section 2030.290 states in part, “If a party to whom interrogatories are directed fails to serve a timely response, the following rules apply: [¶] (a) The party to whom the interrogatories are directed waives any right to exercise the option to produce writings under Section 2030.230, as well as any objection to the interrogatories, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018.010). The court, on motion, may relieve that party from this waiver on its determination that both of the following conditions are satisfied: [¶] (1) The party has subsequently served a response that is in substantial compliance with Sections 2030.210, 2030.220, 2030.230, and 2030.240. [¶] (2) The party's failure to serve a timely response was the result of mistake,