§ 2030.300.300
Title 4. Civil Discovery Act · Chapter 13. Written Interrogatories · Article 2. Response to Interrogatories · Last amended 2020 · Last verified July 29, 2026
Full Text of § 2030.300
Plain-English Summary
A response to interrogatories can comply with the formal requirements of Article 2 and still fall short in substance, and this section is the tool for challenging that shortfall. On receiving a response, the propounding party may move to compel a further response on any of three grounds: an answer to a particular interrogatory is evasive or incomplete rather than responsive in substance, the responding party's exercise of the option to produce business records under Section 2030.230 is unwarranted or its specification of documents is inadequate, or an objection lacks merit or is stated too generally to evaluate.
Procedurally, the motion has to be backed by a meet-and-confer declaration, and the court has discretion to accept a concise outline of the disputed requests and responses in place of the separate statement the Rules of Court would otherwise require, an accommodation aimed at trimming the paperwork on disputes that are not complicated. Timing matters here more than almost anywhere else in the chapter: the propounding party must give notice of the motion within 45 days of the verified response, or any supplemental verified response, or by whatever later date the parties have agreed to in writing, or it waives the right to compel a further response entirely. As with the motion to compel a first response, subdivision (d) requires a mandatory monetary sanction against whichever side loses, absent substantial justification or unjust circumstances, and subdivision (e) lets the court escalate to an issue, evidence, or terminating sanction if a party disobeys an order compelling further response.
Frequently Asked Questions
On what grounds can a party move to compel a further response to interrogatories?
That an answer is evasive or incomplete, that the exercise of the option to produce documents is unwarranted or inadequately specified, or that an objection is without merit or too general.
What is the deadline to move to compel a further response?
Notice of the motion must be given within 45 days of service of the verified response or any supplemental verified response, or by a later date the parties agreed to in writing, or the right to compel is waived.
Must this motion be accompanied by a meet-and-confer declaration?
Yes, a meet-and-confer declaration under Section 2016.040 must accompany the motion.
Can a party submit something less formal than a full separate statement to support the motion?
Yes. The court may allow a concise outline of the discovery request and each disputed response in lieu of the separate statement otherwise required by the Rules of Court.
Is a sanction automatic on a motion to compel a further response?
Generally yes. The court must impose a monetary sanction against whoever unsuccessfully makes or opposes the motion, absent substantial justification or unjust circumstances, with further issue, evidence, or terminating sanctions available if a resulting order is disobeyed.
Amendment History
(Added by Stats.2004, c. 182 (A.B.3081), § 23, operative July 1, 2005. Amended by Stats.2013, c. 18 (A.B.1183), § 1; Stats.2018, c. 317 (A.B.2230), § 3, eff. Jan. 1, 2019, operative Jan. 1, 2020.)