Plaintiff's Motions to Compel Defendant's Responses to Request for Production of Documents and Form Interrogatories are GRANTED.

When a party to whom requests for production of documents are directed fails to respond, under CCP § 2031.300(b) a party propounding the interrogatories may move for an order compelling a response. A party who fails to provide a timely response waives any objection, including one based on privilege or work product. CCP § 2031.300(a). For a motion to compel initial responses, no meet and confer is required. All that needs to be shown is that a set of requests was properly served on the opposing party, that the time to respond has expired, and that no response of any kind has been served.

When a party to whom interrogatories are directed fails to respond, under CCP § 2030.290(b) a party propounding the interrogatories may move for an order compelling a response. A party who fails to provide a timely response waives any objection, including one based on privil