Often, yes, but the fight decides it. Where the court's own words ordered a privilege log or found one inadequate, the motion was granted at least in part in 72 of 77 request sets. Where the court sustained an overbreadth objection, it denied the request in 48 of 63.
Part of a series on motions to compel further responses. Start with the overview: Why Do Motions to Compel Further Responses Lose?
The number
We read 468 California superior court rulings on motions to compel further responses to requests for production (RFPs). They decided 945 RFP request sets. A request set is one set of RFPs from one party.
| Outcome | RFP request sets |
|---|---|
| Further response compelled (in full or in part) | 568 of 945 |
| Denied | 377 of 945 |
What decides it: the issue the court ruled on
The counts below cover only the sets where the court's own words addressed that issue. Other rulings may have turned on the same issue without saying so, so treat each count as a minimum.
| The issue the court decided | What lost | What won |
|---|---|---|
| Did the privilege objection come with a log? | Log found adequate: motion denied in 2 of 2 | Log ordered or found inadequate: granted at least in part in 72 of 77 |
| Was the statement of compliance complete? | Found adequate: motion denied in 8 of 9 | Missing or defective: ordered fixed in 32 of 34 |
| Was the request too broad? | Objection sustained: motion denied in 48 of 63, request cut down in 11 more | Objection overruled: granted in 13 of 14 |
Privilege logs. A privilege objection "shall provide sufficient factual information for other parties to evaluate the merits of that claim, including, if necessary, a privilege log" (CCP § 2031.240(c)(1)). Example: "Furthermore, to the extent that Defendant/Cross-Complainant assert the attorney-work product privilege or work product doctrine they shall provide a privilege log or other like evidence to support their assertions." (Contra Costa, C23-02761, 2025-12-18).
Statements of compliance. The response must state that "all documents or things in the demanded category that are in the possession, custody, or control of that party and to which no objection is being made will be included in the production" (CCP § 2031.220). If the party says it cannot comply, that is a separate statement with its own required content (CCP § 2031.230). Example: "Amendment required. Plaintiff to amend to state whether the documents 'never existed, has been destroyed, has been lost, misplaced, or stolen, or has never been, or is no longer in, the possession, custody, or control of the responding party.' CCP § 2031.230." (San Mateo, 24-CIV-00404, 2026-05-02).
Overbreadth. A demand must designate the documents "either by specifically describing each individual item or by reasonably particularizing each category of item" (CCP § 2031.030(c)(1)). Example: "Plaintiff’s request for ‘all documents’ is unreasonably overbroad." The court added: "The requests contain no limit to vehicles of the same make, model, or year as the subject vehicle." It then limited the request by place and date and granted it in part. (Los Angeles, 25NWCV01606, 2026-05-04).
No time or subject limit was its own problem. In at least 58 sets, the court narrowed or denied a request for that reason: it granted 24 in part (narrowed), denied 20 and granted 14 in full.
What the average hides: the scope fight
Overall, the court compelled a further response in 568 of 945 RFP sets. Where scope was the court's main reason, the result flipped.
| The court's main reason | Compelled (in full or in part) | Denied |
|---|---|---|
| All RFP sets | 568 of 945 | 377 of 945 |
| The response was incomplete | 253 of 279 | 26 of 279 |
| Scope (relevance or overbreadth) | 116 of 258 | 142 of 258 |
The moving side's own paperwork mattered here too. Where the court found no real meet and confer, it denied 18 of 18 RFP sets. Where the motion was late, it denied 22 of 23.
What to do
| If you served the RFPs | If you're responding |
|---|---|
| If they objected on privilege with no log, ask for one. Where the court addressed the log, it granted the motion at least in part in 72 of 77. | If you claim privilege, serve a log or other facts that let the other side test the claim (§ 2031.240(c)(1)). |
| Check the statement of compliance word by word against § 2031.220. Defective statements were ordered fixed in 32 of 34. | Use the statute's words in your statement of compliance or inability to comply (§§ 2031.220, 2031.230). |
| Before you file, narrow "all documents" requests by time and subject. Where an overbreadth objection was sustained, the request was denied in 48 of 63. | If a request is too broad, say how, and point to the missing time or subject limit. |
Method and N: 945 RFP request sets in 468 California superior court tentative rulings on motions to compel further responses, from 7 counties, mostly 2025 and 2026, as of 2026-10-11. This is the RFP part of the same set as the overview. A request set is one set of RFPs from one party in one ruling. The issue counts (privilege log, statement of compliance, overbreadth, time or subject limit) come from a model's reading of the full ruling, used only where the supporting sentence was checked against the ruling. They count only rulings whose words addressed the issue, so they are minimums, not complete rates. The "main reason" table uses the overview's coding of the court's stated reason. These counts describe the court's stated reason, not a predicted chance of winning. These are tentative rulings, and they are not precedent. Nothing here is legal advice. Updated 2026-10-12: counts revised after removing duplicate rulings; no conclusion changed.