CODE OF CIVIL PROCEDURE § 2031.310. Motion for order compelling further response; Notice; Electronically stored information; Sanctions, Cal Code Civ Proc § 2031.310
Summary
(a)On receipt of a response to a demand for inspection, copying, testing, or sampling, the demanding party may move for an order compelling further response to the demand if the demanding party deems that any of the following apply:
(1)A statement of compliance with the demand is incomplete.
(2)A representation of inability to comply is inadequate, incomplete, or evasive.
(3)An objection in the response is without merit or too general.
(b)A motion under subdivision (a) shall comply with each of the following:
(1)The motion shall set forth specific facts showing good cause justifying the discovery sought by the demand.
(2)The motion shall be accompanied by a meet and confer declaration under Section 2016.040.
(3)In lieu of a separate statement required under the California Rules of Court, the court may allow the moving party to submit a concise outline of the discovery request and each response in dispute.
(c)Unless notice of this motion is given within 45 days of the service of the verified ...