Plaintiff filed a MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES (SET ONE) AND RQUEST FOR SANCTIONS. Defendant timely filed an OPPOSITION. No reply was filed. Having read all the papers filed, the court issues the following tentative ruling: Plaintiff failed to file a Separate Statement as required by Cal. Rule of Court, Rule 3.1345(a). Failure to file the separate statement is sufficient basis for denying a motion to compel. Mills v. U.S. Bank (200*) 166 Cal.App.4th 871, 893. However, in its discretion, the court has decided to rule on the motion. On October 23, 2023, Plaintiff dismissed all representative PAGA and class claims. Here, the response to Special Interrogatory No. 8 is at issue. As initially drafted, the interrogatory sought the identity of “all TECHNICIANS who were employed ... at any time between May 1, 2020, and the present.” However, there was substantial meet and confer efforts between the parties. On January 29, 2024, Defendant agreed to produce the id