MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES

MOVING PARTY: Defendant Clarence Kerr

RESPONDING PARTY(S): Plaintiff/Cross-Defendant Steven Jensen

PROOF OF SERVICE:

Defendant Clarence Kerr’s Motion to Compel Further Responses from Steven Jensen

ANALYSIS

Motion to Compel Further Responses to Special Interrogatories

A motion to compel further responses to form interrogatories “shall be accompanied by a meet and confer declaration under Section 2016.040.” CCP § 2030.300(b). In turn, “[a] meet and confer declaration in support of a motion shall state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” CCP § 2016.040. Here, the Declaration of Weiss B. Hamid does not state facts showing a reasonable and good faith attempt at an informal resolution of each issue presented by the motion. Nor do the exhibits attached as Exhs. 3-5 of the Hamid Declaration.

Moreover, on January 8, 2019, Plaintiff Jensen served s