Q: Translation of further discovery response.

A: Under California law, let's analyze the implications of the defense's further discovery responses to the in pro per plaintiff's interrogatories:

1. Meaning of the responses in plain English:

- "Failed to find out identity" suggests the defense has not been able to determine the identities of the individuals referenced in the interrogatory.

- "Responding party will produce for deposition these individuals referenced in the interrogatory" indicates that the defense will make the referenced individuals available for depositions, allowing the plaintiff to question them directly.

- "Further discovery is continuing" implies that the defense is still in the process of gathering information and has not completed its discovery obligations.

2. Defense's potential objectives:

- Delaying the discovery process: By providing vague responses and promising to produce individuals for depositions, the defense may be attempting to prolong the discovery phase and delay the case's progression.

- Withholding information: The defense might be strategically withholding specific details or identities to maintain an advantage or to protect certain individuals.

- Genuine inability to provide information: In some cases, the defense may genuinely struggle to identify the individuals or gather the requested information.

3. Actions triggered for a professional attorney who propounded the interrogatories:

- Follow up with meet and confer: The attorney should attempt to meet and confer with the defense counsel to discuss the inadequate responses and seek clarification or more specific answers.

- Set depositions: If the defense promises to produce individuals for depositions, the attorney should promptly notice and schedule those depositions to obtain the necessary information.

- Motion to compel: If the defense continues to provide evasive or incomplete responses after meet and confer efforts, the attorney may need to file a motion to compel further responses to the interrogatories.

- Continue discovery: The attorney should persist with other discovery methods, such as requests for production of documents or third-party subpoenas, to gather relevant information.

- Consider sanctions: If the defense's conduct appears to be a deliberate attempt to obstruct discovery, the attorney may seek sanctions from the court for abuse of the discovery process.

The defense's vague responses to the in pro per plaintiff's interrogatories appear to be a tactic to delay and withhold information. A professional attorney would need to actively pursue the requested information through meet and confer efforts, depositions, motions to compel, and other discovery tools while considering the potential need for court intervention if the defense persists in providing inadequate responses.