Make or Break Discovery-2. 5-29-12: Opposition mailed unverified, incomplete responses to Spec. Intertogatories, Frm Iroggs, Admissions & Production.
On 7-19-12 motion to compel was served & filed (51st day). The motion contained language to "compel responses" & to "compel further responses". Separate statement rebutted the 5-10 objections per each response & it argued further response. Do I understand correctly:
1. If Unverified responses are no responses then motion to compel is not limited to 45-50 day rule and therefore the 51st day service/filing is okay per ca code civ. proc.?
2. Opposition may still argue they cannot be compelled because their objections (which need not be verified per Blue Ridge v. Sup Ct, 1988) stand, then argument pivots upon showing each/every objection is evasive, vague, and without merit?
3. Only IF their objections are successfully rebutted will we argue the merits of their responses vs. merits to compel further responses?
My 1st concern here is the 51st day service/filing.