Sample Opposition to Motion to Compel Further Responses to Interrogatories for California.

This sample opposition to a motion to compel further responses to interrogatories for California can be used to oppose a motion to compel on several grounds including,

• That the opposing party has already provided adequate responses to the interrogatories,
• The motion to Compel is essentially arguing about form over substance as the motion to compel was filed merely because the moving party does not like the answers,
• The interrogatories clearly do not relate to the claim or defense of the party seeking discovery or of any other party to the action as required by Code of Civil Procedure section 2017.010, and
• The interrogatories are unduly burdensome and oppressive.

The sample opposition also requests sanctions on the grounds that the party filing the motion to compel failed to make a reasonable and good faith effort to meet and confer before filing the motion to compel.

The sample has been revised and updated in March 2018, is 14 pages and includes,

• Brief instructions,
• Memorandum of points and authorities with citations to case law and statutory authority,
• Sample declaration, and
• Proof of service.

The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale.

Note that the author is NOT an attorney and no guarantee or warranty is provided.