MOTION TO COMPEL FURTHER RESPONSES FROM DEFENDANT PARADIES LAGARDERE @ PSP, LLC TO PLAINTIFFS’ SPECIAL INTERROGATORIES, SET ONE BY VASILIOS RALLIS, YAEL RALLIS
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1. CASE # CASE NAME HEARING NAME MOTION TO COMPEL FURTHER RESPONSES FROM DEFENDANT RALLIS VS CITY OF PALM PARADIES LAGARDERE @ PSP, LLC
SPRINGS TO PLAINTIFFS' SPECIAL INTERROGATORIES, SET ONE BY VASILIOS RALLIS, YAEL RALLIS Tentative Ruling: A party may file a motion compelling a further response to requests for production if it finds that a response is inadequate, incomplete, or evasive, or an objection in the response is without merit or too general. (Code Civ. Proc., § 2031.310, subd. (a).)
In a motion to compel a further response as to document requests, the moving party must state facts demonstrating good cause justifying the discovery sought by demonstrating relevance and specific facts justifying discovery. (Code Civ. Proc., §2031.310, subd. (b)(1); Kirkland v. Superior Court (2002) 95 Cal.App.4th 92, 98.) The burden to show good cause for production “is met simply by a fact-specific showing of relevance.” (Tbg Ins. Servs. Corp. v. Superior Court (2002) 96 Cal.App.4th 443, 448.) Once good cause is established, the responding party has the burden to justify any objections. (Kirkland, supra, 25 Cal.App.4th at 98.)
A motion to compel lies where the party to whom the interrogatories were directed gave responses deemed improper by the propounding party; e.g., objections, or evasive or incomplete answers. (Code Civ. Proc., § 2030.300; see Best Products, Inc. v. Sup. Ct. (2004) 119 Cal.App.4th 1181, 1189-1190
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“Each answer in a response to interrogatories shall be as complete and straightforward as the information reasonably available to the permits,” (Code Civ. Proc., § 2030.220, subd. (a).) “If an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Id. at § 2030.220, subd. (b).) “If the responding party does not have personal knowledge sufficient to respond fully to an interrogatory, that party shall so state, but shall make a reasonable and good faith effort to obtain the information...” (Id. at § 2030.220, subd. (c).) The burden is on responding party to justify any objection or failure to provide a complete response. (Fairmont Ins. Co., supra, 22 Cal.4th at 255.)
Defendants provided proof of supplemental responses to Plaintiffs’ SROGs, FROGs, and RFPs on 5/4/2026. Accordingly, the motions to compel are moot as to everything supplemented. Should Plaintiffs contend that Defendants’ supplementation remains deficient, it would be immaterial for purposes of the instant motions. There must be a meet and confer as to any alleged deficiencies for the supplemental responses, and Plaintiff must bring another motion to compel further supplemental responses if the parties cannot resolve the matter. (Code Civ. Proc., § 2031.310 [“Where responses have been made but they are not satisfactory to the demanding party, the motion is to compel further responses”].)
All Motions to Compel are deemed MOOT.