Plaintiffs Joanna Paz and Willie Paz Jr. (collectively “Plaintiffs”) move for an order compelling Defendant FCA US, LLC (“Defendant”) to respond to Plaintiffs’ Request for Production of Documents, Set One (“RFP”), without objections, pursuant to CCP § 2031.300.
Where there has been no timely response to a CCP § 2031.010 demand, the first thing the demanding party must do is to seek an order compelling a response. (See CCP § 2031.300.) Failure to serve a response waives all objections to the inspection demands, unless the judge grants a motion relieving the responding party from that waiver, and entitles the demanding party to obtain an order compelling responses. (CCP § 2031.300(a), (b).)
The response must be signed “under oath” by the party to whom it is directed. That party's attorney must also sign if the response contains an objection. If it consists entirely of objections, only the attorney's signature is required. (CCP § 2031.250.) Where the response contains both agreements to c