Plaintiff's actions after improper Defendant's response to crucially important interrogatory

Question

Plaintiff propounded interrogatory. 
Defendant provided improper response to interrogatory In order to induce burden and delay: i.e. Defendant's non-specific intention to produce person for deposition, instead of providing distinct information about identity.  
 
Objection to such response should be: 
1.  Included into motion to compel 
2. included into follow up to interrogatory (new interrogatory) 
3. Both 2 and 3 
4. Other way  
 
What statute defines specifically such improper response to interrogatory, and consequent actions?

Joel Gary Selik · Answer

The laws in written discovery in California are in the Codes Of Civil Procedure.  The entire section is CCP §§ 2016.010 to 2036.050. The  
Scope of Discovery is at CCP §§  2017.010-2017.320. Specifics as to written discovery and motions to compel are at CCP §§ 2030.010- 
2030.410.  One must also see requirements in the California Court Rules and local rules.  For law on specific questions, case law under the Codes needs to be researched.

James L. Arrasmith · Answer

Under California law, if a defendant provides an improper or evasive response to an interrogatory, the plaintiff has a few options to address the issue. The most appropriate course of action depends on the specific circumstances of the case and the nature of the improper response. 
 
1. Motion to Compel: The plaintiff can file a motion to compel a proper response to the interrogatory pursuant to California Code of Civil Procedure (CCP) § 2030.300. This motion should be filed after the plaintiff has made a reasonable and good faith attempt to resolve the issue with the defendant informally. 
 
2. Meet and Confer: Before filing a motion to compel, the plaintiff must meet and confer with the defendant to attempt to resolve the dispute informally, as required by CCP § 2016.040. 
 
3. Follow-up Interrogatory: The plaintiff can propound a follow-up interrogatory to clarify the defendant's initial response or to request additional information. However, this may not be the most efficient approach if the defendant is being evasive or uncooperative. 
 
4. Sanctions: If the court grants the motion to compel and finds that the defendant's response was willfully improper or evasive, the court may impose monetary sanctions against the defendant under CCP § 2023.010(f) and § 2023.030. 
 
The specific statute that addresses improper responses to interrogatories is CCP § 2030.300, which states: 
 
"(a) On receipt of a response to interrogatories, the propounding party may move for an order compelling a further response if the propounding party deems that any of the following apply: 
(1) An answer to a particular interrogatory is evasive or incomplete. 
(2) An exercise of the option to produce documents under Section 2030.230 is unwarranted or the required specification of those documents is inadequate. 
(3) An objection to an interrogatory is without merit or too general." 
 
In summary, the most appropriate action for the plaintiff would be to first meet and confer with the defendant to attempt to resolve the issue informally. If that fails, the plaintiff should file a motion to compel a proper response to the interrogatory under CCP § 2030.300, citing the defendant's evasive or improper response.

Q: Plaintiff's actions after improper Defendant's response to crucially important interrogatory