The other side's discovery responses fall short, so you move to compel. About half the time, the court orders better answers. But 162 of the 848 denials came from the moving side's own paperwork.
The number
We read 780 California superior court rulings on motions to compel further responses. They decided 2,134 request sets. A request set is one set of requests, such as one set of RFPs, from one party.
| Outcome | Request sets |
|---|---|
| Granted in full | 1,092 of 2,134 |
| Granted in part | 194 of 2,134 |
| Denied | 848 of 2,134 |
The method matters a little. Form interrogatories were granted in full most often, in 184 of 327. RFAs were close to even: granted in full in 74 of 171 and denied in 87 of 171. We will cover each method in follow-ups.
This piece is about motions to compel further responses, after the other side has served responses. If the other side served nothing, that is a different motion.
What decides it
Each count below covers only the request sets where the court gave that reason.
| The issue the court decided | What lost | What won |
|---|---|---|
| Did you meet and confer on each issue? | No real meet and confer: denied in 82 of 82 | No separate count |
| Did you file within 45 days? | Filed after the deadline: denied in 80 of 84 | No separate count |
| Were the responses complete? | No separate count | Responses incomplete or evasive: granted in full in 623 of 768 |
Meet and confer. The motion "shall be accompanied by a meet and confer declaration under Section 2016.040" (CCP § 2031.310(b)(2)). That declaration "shall state facts showing a reasonable and good faith attempt, either in person, by telephone, or by videoconference, to informally resolve each issue presented by the motion" (CCP § 2016.040(a)). Examples: "The motion is DENIED for lack of a good faith meet and confer." (Los Angeles, 24SMCV05086, 2026-05-29). "Consequently, because Plaintiff has not satisfied the statutory requirements of California Code of Civil Procedure Section 2016.040(b), Plaintiff’s motions are denied on procedural grounds." (Orange, 30-2022-01262979, 2026-07-14).
The 45-day deadline. "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 demanding party and the responding party have agreed in writing, the demanding party waives any right to compel a further response to the demand" (CCP § 2031.310(c)). The rules for interrogatories (CCP § 2030.300(c)) and RFAs (CCP § 2033.290(c)) use almost the same words. Example: "Plaintiffs’ motion to compel further responses to Requests for Production of Documents and Things, Set Five, is DENIED as untimely under Code of Civil Procedure section 2031.310(c)." (Los Angeles, 23BBCV00639, 2026-05-19).
Incomplete responses. This was the moving side's strongest position. Example: "The Motion is granted as to RFP nos. 20-21 because it is not apparent that Defendant produced all responsive documents, with Plaintiff able to point to documents within her own possession that were not provided." (Los Angeles, 25STCV09964, 2026-06-15).
What the average hides: which objections held up
Overall, the motion was granted in full in about half the request sets (1,092 of 2,134). By objection, the picture changes: boilerplate almost never held, and overbreadth usually did.
| Objection the court ruled on | Motion granted in full | Motion denied |
|---|---|---|
| Boilerplate objections | 114 of 129 | 2 of 129 |
| Privacy | 66 of 108 | 27 of 108 |
| Privilege | 52 of 96 | 23 of 96 |
| Overbreadth or scope | 128 of 387 | 209 of 387 |
The rest of each row was granted in part.
Boilerplate. "Granted. DRH’s sixteen (16) objections incorporated into to [sic] each response, taken as a whole, constitute impermissible boilerplate objections and, as such, are overruled." (Contra Costa, C23-02347, 2025-12-17).
Privacy. "The Motion is granted as to the SIs. The objections lack merit and the contact information should be produced." (Los Angeles, 25STCV09964, 2026-06-15).
Overbreadth. The court can also narrow a request instead of denying it: "The Court finds that the request for FEHA claims for the past 10 years preceding Plaintiff’s claims are overbroad in scope. This objection is sustained. DRH is ordered to produce three (3) years of prior FEHA claims made against DRH." (Contra Costa, C23-02347, 2025-12-17, granted in part).
What to do
| If you're moving to compel | If you're responding |
|---|---|
| Meet and confer on each issue in person, by phone or by video. Put the facts in your declaration. With no real meet and confer, 82 of 82 request sets were denied. | Drop boilerplate. Where the court ruled on boilerplate objections, it granted the motion in full in 114 of 129. |
| Count 45 days from service of the verified response. If you need more time, get the extension in writing. Late motions were denied in 80 of 84. | If a request is too broad, say exactly how. Overbreadth objections held in 209 of 387. |
| Point to what is missing. Where the court found the responses incomplete or evasive, it granted in full in 623 of 768. | Do not rely on a privacy label alone. The court granted the motion in full over a privacy objection in 66 of 108. |
Method and N: 2,134 request sets in 780 California superior court tentative rulings on motions to compel further responses to RFPs, interrogatories and RFAs, from 7 counties, mostly 2025 and 2026, as of 2026-10-11. A request set is one set of requests from one party in one ruling. We left out motions to compel initial responses, motions to deem RFAs admitted, and rulings that were continued, off calendar or not reached. Of the 848 denials, 77 came after the other side served new responses once the motion was filed. Duplicate captures of the same ruling were removed. The reasons are the court's stated reasons, coded by a model and hand-checked on a sample of 12. 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.