Motion to Compel Further Responses to Requests for Admissions
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Michael Sandoval v. MOM SLO, LLC, 25CV-0210
Hearing: Motion to Compel Further Responses to Requests for Admissions
Date: June 11, 2026
MOM SLO, LLC (Defendant) is moving to compel further responses to Requests for Admissions (RFA), Set One from Michael Sandoval (Plaintiff), and for the imposition of sanctions pursuant to Code of Civil Procedure section 2033.290. Plaintiff opposes and requests imposition of sanctions against Defendant.
The motion is granted in part, denied in part.
I. LEGAL STANDARD
“Most of the other discovery procedures are aimed primarily at assisting counsel to prepare for trial. Requests for admissions, on the other hand, are primarily aimed at setting at rest a triable issue so that it will not have to be tried. Thus, such requests, in a most definite manner, are aimed at expediting the trial. For this reason, the fact that the request is for the admission of a controversial matter, or one involving complex facts, or calls for an opinion, is of no moment. If the litigant is able to make the admission, the time for making it is during discovery procedures, and not at the trial.” (Cembrook v.
Superior Court in and for City and County of San Francisco (1961) 56 Cal.2d 423, 429.) Other discovery devices “principally seek to obtain proof for use at trial. In marked contrast, admission requests seek to eliminate the need for proof.” (St. Mary v. Superior Court (2014) 223 Cal.App.4th 762, 775.)
A propounding party may move to compel further responses to requests for admission if he or she deems an objection is meritless or too general and/or an answer is evasive or incomplete. (Code Civ. Proc., § 2033.290, subd. (a).) A party may respond to a request for admission by asserting an objection. (Code Civ. Proc., § 2033.230.) The objecting party bears the burden of justifying any objections raised. (
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II. DISCUSSION
Defendant moves to compel further responses to RFA Nos. 1-13.
A. RFA Nos. 3-10, 12-13
In response to RFA Nos. 3-10, 12-13, Plaintiff denied each request, subject to asserted objections. However, Plaintiff does not address his objections, nor does he support them in any way in his opposition papers. Plaintiff as the responding party fails to meet his burden. (Fairmont Insurance Company v. Superior Court (2000) 22 Cal. 4th 245, 255 [the burden is on the responding party to justify any objection if a timely motion has been filed].) Thus, the undefended objections are overruled.
Although objections to these RFAs have been overruled, further responses are not warranted because Plaintiff has unequivocally denied each RFA. It is held that where a response contains an unequivocal denial, there are no grounds to compel a further response, even if the facts involved are unquestionably true. (Holguin v. Superior Court (1972) 22 Cal.App.3d 812, 820 [A court cannot force “a litigant to admit any particular fact if he is willing to risk a perjury prosecution or financial sanctions.”]; See Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2025) ¶ 8:1332.1; Moore & Thomas, Cal. Civ. Practice Procedure (2026) § 13:201 [motion limitations].) Accordingly, the Court denies the motion to compel further responses to RFA Nos. 3-10, 12-13.
B. RFA Nos. 1, 2
In response to RFA Nos. 1 and 2, Plaintiff provided qualified denials, subject to asserted objections. As the previously mentioned RFAs, Plaintiff fails to address or support his objections. Plaintiff’s objections are overruled.
The Court denies the motion to compel further responses to RFA Nos. 1 and 2, on the ground that these responses constitute statutorily compliant qualified denials. (Code Civ. Proc., § 2033.220, subd. (b)(1); See St. Mary v. Superior Court, supra, 223 Cal.App.4th 762, 780 [“Although ‘[a] denial of all or any portion of the request must be unequivocal [citation] ... reasonable qualifications are not improper.’ [Citation.]”].)
C. RFA No. 11
Discovery is generally allowed for any non-privileged matters that are relevant to the subject matter involved in the action “if the matter either is itself admissible in evidence or appears reasonably calculated to lead to the discovery of admissible evidence.” (Code Civ. Proc, § 2017.010.) Information is relevant to the subject matter if it might reasonably assist a party in evaluating the case, preparing for trial, or facilitating settlement. (Gonzalez v. Superior Court (1995) 33 Cal.App.4th 1539, 1546.)
Plaintiff objects to RFA No. 11 based on lack of relevance. Plaintiff argues RFA No. 11 seeks irrelevant information. “The relevance objection was likewise properly preserved. [W]hether a brick-and-mortar employee was available to assist Plaintiff has no bearing on the websiteaccessibility issues that are the subject of this lawsuit, and the ADA prohibits requiring a person with a disability to rely on an in-person workaround instead of full and equal access to the channel of communication actually offered to non-disabled patrons. (See 28 C.F.R. § 36.202.) The response is complete and code-compliant.” (Pl. Sep. Statement, p. 10, ll. 2-7.)
Plaintiff has not demonstrated that Defendant’s inquiry is irrelevant under the broad standard governing discovery. The Court finds no basis to conclude the information sought falls outside the scope of permissible discovery. The objection is overruled.
RFA No. 11, states that “Plaintiff has made a reasonable inquiry and is unable to admit or deny the request because Plaintiff does not have knowledge of what Defendant’s employees would or would not do as he has been deterred from patronizing Defendant’s brick and mortar store.” (Pl.
Sep. Statement, p. 9, ll. 10-12.) The Court finds this response to be evasive. Plaintiff is ordered to provide a further response to RFA No. 11, without objections.
D. Sanctions
Monetary sanctions sought by both sides are denied, as imposition of sanctions make the imposition of sanctions unjust. (Code Civ. Proc., § 2033.290, subd. (d).)
No sanctions are awarded to either party. Although Defendant successfully challenged Plaintiff’s objections, the Court declines to order further responses to RFAs 1-10, 12, and 13, and therefore no sanctions are awarded against Defendant for bringing this motion. For the same reason, because no further responses are ordered to those RFAs, no sanctions are awarded against Plaintiff.
ORDER (PROPOSED)
Defendant’s motion to compel further responses by Plaintiff to Requests for Admission, Set No. 1 is granted in part and denied in part. No further responses are required for RFAs 1-10, 12, and 13. Plaintiff shall serve further responses conforming to the requirements stated in Code of Civil Procedure section 2033.220 subdivision (b) to RFA No. 11, within 20 days of this ruling.
Neither party is awarded sanctions, as the specific circumstances of this case make their imposition unjust. (Code Civ. Proc., § 2033.290, subd. (d).)
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