Motion to compel request for admissions california. The case of Vidal Sassoon, Inc.

2030. (b). Bell filed concurrently herewith, and such The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; The Onglyza Product Cases, A165387 decided on April 19, 2023 by the First District Court of Appeal is a case to be aware of. A motion to compel is an application to a trial court for an order commanding a party's compliance with one or more provisions of the Civil Discovery Act. Horan,Deputy Clerk 1 State BarNo. You simply serve an amended response that complies with the California Rules of Court and the Code of Civil Procedure sections applicable to interrogatories. § 2031. 1, Refs & Annos michellawyers. In form and substance a Rule 36 admission is comparable to an admission in pleadings or a stipulation drafted by counsel for use at trial, rather than to an evidentiary admission of a party. 1 See, e. ) The verified response is to be made by the party instead of counsel because the party, as the person or entity in possession, custody, or control of the requested document(s), has Except as provided in 3. (Declaration of Scott M. 00 for legal fees, $40 for filing the motions to compel and $1,642. The sample motion also requests sanctions. > > Read More. 290, which is the wrong statute. B4. 290 and can be used when the opposing party has provided evasive or incomplete answers or has used generic boilerplate objections. . App. To deny defendant’s motion to compel plaintiff to provide further responses to requests for admission nos. The truth of the matters specified in the Requests for Admissions, Set One, are to be deemed admitted unless plaintiff Dwayne Williams serves, before the hearing, a proposed response to the Requests for Admission that is in substantial Except as provided in 3. Endnote. Chong 2 3325 Wilshire Boulevard The Court May Compel A Party To Provide Further Answers To Discovery (Requests For Admissions) Pursuant to Code of Civil Procedure §2033. 1, which seeks Clement at 1284 The Referee recommended that the motion to compel further responses be granted and that plaintiffs were to reimburse defendant $4,950. A party must respond to written discovery (Form Interrogatories, Special Interrogatories, Requests for Production, and Requests for Admissions) within 30 days of service (35 days if by mail). 99 which is a discount of over 65% off! What is a Motion to Compel? A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena. 040. 010 et seq. 8685 • F: 310. Oct 26, 2021 · motion to compel - motion to compel initial responses [motion compel 2 of … Preview Electronically FILED by Superior Court of California, County of Los Angeles on 09/30/2019 08:47 AM Sherri R. 8685T: 1 1777 San Vicente Blvd. 280(c). ) Jul 10, 2023 · In my Discovery Referee cases I am seeing more motions going to the brink with one party bringing a motion for issue, evidence and/or terminating sanctions. , §§ 2030. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission;. , § 2016. ” Is the court correct?” Continue Reading DISCOVERY GAMES AND MISCONCEPTIONS – Is the Court Correct That There is No Motion to Strike in Discovery? Plaintiffs have filed two motions to compel, and this opposition brief addresses both motions. 300. 280, subd. SELARZ (State Bar No. The main purpose of Requests for Admissions is to set issues to rest by compelling admissions of The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; Jan 18, 2017 · This sample motion to compel further responses to requests for admission in California is filed under the provisions of Code of Civil Procedure section 2033. Jun 26, 2023 · Summary. Many of the motions are denied without prejudice due to the papers being deficient in showing a history of abuse and prejudice to the propounding party that warrant the granting of the motion. Prior to serving a motion for summary judgment/summary adjudication, so you know whether the opposing party has information that could defeat your motion. Skip to main content. Jan 1, 2023 · (c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or on or before any specific later date to which the propounding party and the responding party have agreed in writing, the propounding party waives any right to compel a further response to the interrogatories. , Suite 702 . 50 for defendants portion of the Discovery Referee’s fees for a total sanction of $6,632. 290(b) , 2031. 310(c) (Inspection Demands); 2033. A Motion to Compel is governed by Federal Rule of Civil Procedure 37 and Central District of D1089346-CU-WT-C)JC - ROA #76 - DAVID H. This guide contains forms and instructions for a Motion to Compel Discovery Responses, to be used if the other side in your California civil case completely fails to respond to your requests for production of documents, form interrogatories, or special interrogatories. This must be done as soon as possible so you have the information prior to the filing of your opposition. (See Code Civ. . 300(c) (Interrogatories); 2031. § IN THE DISTRICT COURT OF Plaintiff § § v. Box 2238 5/17/2024 4:25 PM Colton, CA 92324 3 Tel. Franklin in Support ofMotion to Compel Further 12 Responses to Requests for Admissions, Set One, Propounded on Defendants Kamala Harris and 13 Stephen Lindley Ex. Requests for Admissions are the most useful. Requests for Admission Article 1. See CCP §§2030. 3d 545, 551 [225 Cal. Requests for Admission CA CIV PRO Pt. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. 1345(b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. FURTHER RESPONSES TO REQUEST FOR ADMISSION NUMBER 33; MEMORANDUM OF POINTS AND Joan E. [#] and Request for Attaching Exhibits Include Request for Admissions/Proof of Service: All Motions to Compel Response must have at least two exhibits attached: 1. (3) Specific Motions. In my blogs and at seminars, I have advised parties to prepare their meet and confer letters in the format of a separate statement. 210. 040; (4) Separate Statement of items in dispute in compliance with California Rules of Court, rule 3. 010 and 2033. Fla. Panic sets in. App. The motion is filed and served. Since judges do not welcome multiple motions to compel further responses addressing the same requests for admissions, parties should make clear in their motions to compel further responses that the motions are required by section 2033. O. Apr 6, 2016 · Plaintiff’s motion will be made pursuant to Code of Civil Procedure sections 2033. ” What do you do? You are in a real dilemma now. Petitioner A. , 702 Suite 16 DEFENDANT AND DEFENSE COUNSEL IN THE SUM OF $1,060. 10 et seq. ” (Id. (c). 1 With regard to their motion to compel further responses to their form interrogatories, plaintiffs If defendants will still not comply after the meet and confer process, seek an informal discovery conference (“IDC”) if required in the particular jurisdiction, and file a motion to compel. It is used to seek information that the opposing party is refusing to give voluntarily through discovery. (a) On receipt of a response to requests for admissions, the party requesting admissions may move for an order compelling a further response if that party deems that either or both of the following apply: (1) An answer to a particular request is evasive or incomplete. § HARRIS COUNTY, TEXAS § CADENCE McSHANE CONSTRUCTION § COMPANY, LLC § Defendant § 165" JUDICIAL DISTRICT THIRD-PARTY DEFENDANT GORRONDONA’S RESPONSE TO THIRD-PARTY PLAINTIFF CADENCE McSHANE’S MOTION TO COMPEL Third-Party Defendant GORRONDONA & ASSOCIATES, INC. R. 50. 290, 1 subdivision (d). 300(c), 2031. Preparing required fee and cost documentation Nov 15, 2020 · A Motion to Compel Discovery Responses in California under CCP § 2030. Cal. 4, Ch. P. Jul 12, 2024 · Compel Response to Request for Admissions, Ch. The sample is 21 pages and includes brief If the other party in your case fails to respond to your Requests for Admissions in a California civil case, you can move for an order that all admissions are deemed to be true. 290, on receipt of a response to a request for admissions, the party propounding the request may move for an order compelling further response to the request if the answer to a particular request is evasive A motion for an order to a nonparty must be made in the court where the discovery is or will be taken. (2) An objection to a particular request is without merit or too general. MOTION TO COMPEL FURTHER RESPONES TO REQUESTS FOR ADMISSION SELARZ LAW CORP. (d) Each request for admission shall be full and complete in and of itself. 1345; and (5) Proposed Order. 220 [“. The case of Vidal Sassoon, Inc. 07 (1963); 2A Barron & Holtzoff, Federal Practice and Procedure §838 (Wright ed. 83-86 and 88-89; and • Motion to Compel Further Responses to Form Interrogatory 17. Compel Response to Interrogatories, Section 84. The party propounding requests for admissions may move for an order compelling responses under Rule 1. ) As to the Request for Admissions, the motion is brought only pursuant to Code of Civil Procedure section 2030. 300 Article 2. Unless the court determines that the responding party “has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with Section 2033. : 30-2019-01089346 ALI AKTURK May 17, 2024 · The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel or to quash the production (c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or any specific later date to which the requesting party and the responding party have agreed in writing, the requesting party waives any right to compel further response to the requests for admission. 290 and 2023. Except as provided in 3. Mar 9, 2011 · The propounding party may bring a Motion to Compel Further Responses or bring a Motion for Admissions to be Deemed Admitted if the answering party has not made a reasonable inquiry or has access to “readily available” information that would enable to admit or deny the matter. , Suite 702 Los Angeles, California 900 49 T: 310. 3d 681 at 685 (Pre If you do not, the requesting party may file a motion to have the facts deemed admitted by the court, or a motion to compel further responses, both of which may carry sanctions (monetary penalties) against you. The Motion to Compel Further Response to Form Interrogatory 17. 1345. 310(c) and 2032. 73; California Points and Authorities, call number KFC1010 . 220,” it must order the RFAs deemed admitted. Read the code on FindLaw made in response to a request for admission only on leave of court Jun 1, 2016 · The discovery devices listed in order of most the useful to least useful for these motions are: (1) Requests for Admissions (2) Depositions (3) Interrogatories (4) Requests for Production of Documents. 00 SELARZ 17 Filed Concurrently with Notice of Motion 18 and Motion to Compel Further Responses, Without Objections, to Requests for 19 Admission, Set No. a copy of the discovery request (including the signed Proof of Service showing the date and method of service on the responding party) and 2. Strickland (State Bar No. 165966) COUNTY OF SAN BERNARDINO LAW OFFICES OF MICHELLE D. ) Aug 21, 2012 · If the responding party says they don’t have any further information, then you need to solidify that point by either way of a motion to compel further responses, requests for admissions or motion in limine so no further information can be admitted at trial. CRC 335(a) states that “(a)ny motion involving the content of a discovery request or the responses to such a Except as provided in 3. g. • Can be sent to parties only: Only depositions can compel nonparties to give information About I am a litigation lawyer, licensed to practice law in the State of California. Motion to Compel Discovery. at 301. 010). 300 is a legal action taken when a party fails to serve timely responses to discovery requests, such as interrogatories or requests for production. 8681 SELARZ LAW CORP. 2018-86171 FIRST INDUSTRIAL, L. 040 requires that parties meet and confer in a “reasonable and good faith attempt at an informal resolution of each issue Aug 3, 2013 · This sample motion to compel further responses to requests for admission in California is filed under the provisions of Code of Civil Procedure section 2033. Franz E. The propounding party may not effectively in the same motion convert alleged defective responses based upon responses that are legally insufficient into an all or nothing motion. 290(a) provides that a party propounding interrogatories, who has not received timely responses, may move for an order compelling responses to those Before a Motion to Compel sufficient responses can be filed, California requires the parties to engage in a “reasonable and good faith attempt at an informal resolution of each issue presented by the motion. 651. Carter, Executive Officer/Clerk of Court, by M. 710). 5. Discovery Law and Motion Authorities Orange County Bar Association Hon. 300(a); (2) pay a fee of $20 per subpoena Mar 16, 2023 · To deny defendant’s motion to compel plaintiff to provide further responses to Special Interrogatories Nos. Derby Cycle Corp. No preface or instruction shall be included with a set of admission requests unless it has been approved under Chapter 17 (commencing with Section 2033. com Nov 20, 2023 · Admissions 6-36 without objections that unambiguously admit or deny each request by November 30, 2023. A motion to compel can be filed against an opposing party for the failure to respond to discovery requests or if the response is insufficient. v. 280. 310(c) (takes effect 01/01/2020); see Sperber v. 300(b) and 2033. your young associate to file a motion compel further responses. 420, subdivision (b)(1) and Wimberly v. Compel Production or Inspection, Section 85. The second is a motion to compel further responses. Plaintiffs' motions include: • Motion to Compel Further Responses to Requests for Admissions, which seeks further responses to RFA Nos. in regard to interrogatories and 2031. 210-2033. No CRC 335 statement. Robinson (1994) 26 Cal. 8681 TO THE COURT, ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on [Date], at [Time] or as soon thereafter as the matter Specifically, a separate statement is required to accompany any of the following motions to compel a discovery response: • Motion to compel further responses to requests for admission • Motion to compel further responses to interrogatories • Motion to compel further responses to a demand for inspection of documents or tangible things Jul 12, 2024 · The modifiable sample templates contained in this guide are adapted from several library resources, including How to Manage a Contested Divorce in California (no longer in print), CEB Family Law Financial Discovery, California Civil Discovery Practice, California Forms of Pleading & Practice, and many more. (A) To Compel Disclosure. ) Aug 3, 2022 · 5 separate statement in support of motion to compel further responses to plaintiffs’ first set of requests for production of documents 1 2 3 Dec 18, 2023 · Step 1: Determine if Bringing a Motion to Compel Is Proper. (b) Feb 20, 2012 · You need to do separate motions to compel. Los Angeles, California 90049 . Jonathon Appleton (Appleton) seeks a writ of mandate directing respondent superior court to grant his request for sanctions, based on his contention that under the new discovery act sanctions are mandatory upon the granting of a motion to have requests for admission deemed admitted. The case involved 13 California state cases coordinated under a Judicial Council Coordination proceeding (JCCP) regarding the drug of Onglyza and Kombiglyze which contained the active ingredient saxagliptin a medicine for type 2 diabetes. Proc. 2033. Lawyer guide on motions to compel in Sacramento, California. (Id. 6. Now what do you do? The first thing you do is pick up the phone and call opposing counsel and Except as provided in 3. ) “[A] deemed admitted order establishes, by judicial fiat, that a Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. The collection sells for only $109. will be included in the production. Compel Response to Request for Admissions, Section 86. 4th 736, 7454. 635] [verification requirement in answers for requests for admissions propounded pursuant to § 2033]. 1 1777 San Vicente Blvd. ” But what do you actually have to do to meet that requirement? California Code of Civil Procedure section 2016. We agree and shall order the writ to issue. 290(c) (Requests for Jan 12, 2010 · so you won’t get spontaneous answers or admissions • Not good for broad questions: no chance for immediate follow-up questions; vague answers are difficult to clarify. Motion to Compel Discovery Superior Court of California San Diego Timing 45 Days After Insufficient Responses to Written Discovery. Nov 16, 2020 · Before moving to compel discovery responses, California law requires that the parties “meet and confer. , CCP § 2031. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Jun 12, 2024 · However, when a party fails to respond to requests for admissions, the proper motion is for deemed admissions, not to compel a response. files this response to (1) To compel further responses to requests for admission; 10 11 (2) To compel further responses to interrogatories; 12 13 (3) To compel further responses to a demand for inspection of documents or 14 tangible things; 15 16 (4) To compel answers at a deposition; 17 The Motions Motions to Compel Further Responses and Motions for Requests for Admissions be Deemed Admitted must be in your arsenal. See Broward County – 17th Circuit Court SmartRules™ procedural guide: MOTION TO COMPEL. 380. Aug 20, 2019 · If you decide to amend an interrogatory response, you don’t need get a court order (CCP 2030. 300 2033. To gain a strategic advantage, it is important that you file your motion to compel before the defense files a motion for protective order. Home Jan 30, 2017 · The California discovery document collection contains over 50 documents related to discovery such as special interrogatories, motions to compel, requests for admission and requests for production of documents. Response to Requests For Admission CODE OF CIVIL PROCEDURE SECTION 2033. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the Adding to the confusion, the code sections providing for when a motion to compel further discovery responses may be brought, include the scenario where: “An objection to [a discovery request] is without merit or too general. (a) The party to whom requests for admission have been directed shall respond in writing under oath separately to each request. Skip to navigation. All further responses ordered shall be verified and served without objections within Except as provided in 3. 310(a)) or file a motion for relief under CCP §473. 4, T. 287555) dselarz@selarzlaw. Telephone: 310. By this is meant, a propounding party cannot bypass four steps of the statutorily required process by making a Totah (1986) 180 Cal. This guide covers motions to compel interrogatories, document requests, and admissions. (d) With regard to their motion to compel further responses to their request for admissions, plaintiffs sought $3,060 in monetary sanctions pursuant to Code of Civil Procedure sections 2023. 1. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; The court then separated the motions to compel from the motions to strike and refused to rule on the motion to strike stating “There is no such motion. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (c) Each request for admission in a set shall be separately set forth and identified by letter or number. When served with a motion for summary judgment/summary adjudication. compel discovery in California for use in an out-of-state proceeding, the out-of-state party must: (1) submit the original subpoena from the foreign jurisdiction where the case is pending (or a true and correct copy), see Cal. Apr 25, 2011 · After a long stretch of depositions, coupled with intense mediation sessions you finally have a day in the office to clean off your desk and catch up on your other cases Going through the stacks of mail, you find the motion with teeth -the Motion to Have Admissions be Deemed Admitted. 290 on the grounds that the responses to the requests for admission are not code compliant in that they consist of evasive answers and boilerplate objections. CCP §§ 2030. 1961). Twenty days later you get the tentative ruling--“Motion Denied. 11777 San Vicente Blvd. Sitzer, Esq. ”] 2 “A statement that the party to whom a demand for inspection, copying, testing, or sampling has been directed will comply with the particular demand shall state that the production, inspection, copying, testing, or sampling, and related activity demanded, will be allowed either in whole or in part, and Los Angeles, 900 49 California MONETARY SANCTIONS AGAINST T: 310. T A B L E O F C O D E S O F C I V I L P R O C E D U R E Chapter 16. This Plaintiff’s Motion to Compel Further Responses to various discovery includes a (1) Notice of Motion; (2) Memorandum of Points and Authorities; (3) Meet and Confer Declaration pursuant to Code of Civil Procedure section 2016. Jan 12, 2016 · 4. Civ. (Code of Civ. in regard to document production requests. P. Though they appear to be the same motion you would use with the other discovery devices, there are a few noteworthy twists and turns. Sufficiency of Answer Jan 1, 2023 · California Code of Civil Procedure CCP CA CIV PRO Section 2033. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; Sample Motion to Compel further answers to requests for admission in California. Sacramento County Public Law Library. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; . Oct 24, 2023 · To grant defendant Jaene Ojeda Mendoza’s request to deem Requests for Admissions admitted. SIIIICIsLAXD SAN BERNARDINO DISTRICT 2 P. If a party fails to make a disclosure required by Rule 26(a), any other party may move to compel disclosure and for appropriate sanctions. As that email predated the Motions, Defendants have never responded to 14 the Motions’ arguments as to how Proposition 26 should be interpreted. Different CCP setions govern motions to compel further responses to interrogatories and motions to compel fuirther responses to request for production of docuements. By contrast, here after objecting to the entire request for admission, the Local’s admissions and/or denials provided complete responses to the requests, thus leaving nothing to address in a motion to compel. : (951) 782-… 4 pages CAUSE NO. Code § 2029. Please see the Resources tab for a Dec 12, 2020 · Motions to compel further responses to requests for productions of documents require that the motion be filed within 45 days. By delaying the filing of the motion the party waives the right to compel further responses. , SBN 239986 Sitzer Legal 930 E Santa Ana Blvd Santa Ana, CA 92701 (t) 800-420-8653; (f) 888-458-1559 Attorney for Plaintiff, Ali Akturk SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE Case No. ) Mar 1, 2021 · The biggest burden in bringing motions to compel further responses is the preparation of the separate statement of items in dispute pursuant to CRC, Rule 3. 010 and shall be based upon this notice of motion and the memorandum ofpoints and authorities attached hereto, the Separate Statement of Disputed Requests and Responses and the Declaration of Rodney W. , subd. You can reach me by phone at (310) 286-2000. com . This sample motion to compel further answers to requests for admission in California is filed pursuant to the provisions of Code of Civil Procedure sections 2023. 2-6, 9-14. Request for Preview ELECTRONICALLY FILED SUPERIOR COURT OF CALIFORNIA 1 Michelle D. 16, Art. Louisell, Modern California Discovery §8. 3). ) The best approach? Follow up on any objections with a motion to compel following reasonable attempts to meet and confer. On August 24, 2018, I served the foregoing document described herein as NOTICE OF MOTION AND MOTION TO COMPEL RESPONSES TO PLAINTIFF GARY STOLTENBERG’S REQUEST FOR ADMISSION TO DEFENDANT D’ANDREA VISUAL COMMUNICATIONS, SET ONE; AND REQUEST FOR SANCTIONS, on the interested parties in this action by placing a true copy thereof enclosed in a Motion to Compel. § 2033. Because Feb 4, 2014 · (b)). 3, 5, 6, 7. Aug 23, 2021 · Learn about the Motion to Compel Deposition in California, including its purpose, structure, meet and confer requirements, and potential sanctions. FAILURE TO RESPOND There is no time limit on bringing the motion to compel the response to the Interrogatories, or the request for production of documents, or have the admissions be deemed admitted. (B) To Compel a Discovery Response. : 201409 Law Offices of Edward J. Motion for Requests for Admissions be Deemed Admitted This motion is quick and MOTION TO COMPEL FURTHER RESPONES TO REQUESTS FOR PRODUCTION SELARZ LAW CORP. If a party to whom requests for admission are directed fails to serve a timely response, the following rules apply: (a) The party to whom the requests for admission are directed waives any objection to the requests, including one based on privilege or on the protection for work product under Chapter 4 (commencing with Section 2018. a copy of your meet & confer correspondence. Rptr. Jan 1, 2023 · (2) The motion shall be accompanied by a meet and confer declaration under Section 2016. 1 is GRANTED with respect to those request for admission that are not an unqualified admission and DENIED with respect to the other Form Interrogatories to which the motion Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or any specific later date to which the requesting party and the responding party have agreed in writing, the requesting party waives any right to compel further response to the requests for admission. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; MOTION TO COMPEL FURTHER RESPONES TO SPECIAL INTERROGATORIES SELARZ LAW CORP. Apr 1, 2020 · In each separate motion (FROGS, SPROGS, RFP, RFA, Motion to compel depo, etc) you will also need to include the following: 1) notice of motion, 2) memorandum of points and authorities, 3) a separate statement -- which specifically breaks down each question asked, 4) a declaration, 5) proposed order, and 6) proof of service. (3) In lieu of a separate statement required under the California Rules of Court, the court may allow the moving party to submit a concise outline of the discovery request and each response in dispute. , § 2033. 2005 California Code of Civil Procedure Sections 2033. DANIEL E. C. YAMASAKI, Clerk of the Court By Giovanni Galon, Deputy Clerk Andrew D. This often makes it impossible for the other party to win the case. 370(a). (See CCP 2030. 220. 030, subdivision (a), and 2033. 280 . Miller Selected Authorities re Discovery Motions Motions to Compel Responses Interrogatories California C. ” (Code Civ. Jun 17, 2021 · The court shall grant a motion to deem admitted requests for admissions, “unless if finds that the party to whom the requests for admission have been directed has served, before the hearing on the motion, a proposed response to the requests for admission that is in substantial compliance with § 2033. Superior Court (1983) 147 Cal. pa up md kl bl ax ga hc sy rn