Legal Question in Credit and Debt Law in California

I intend to file soon post judgment motion for order imposing issue sanction on debtor for disobeying order to state his date of birth, place of birth, name of father, and maiden name of mother in answer to my interrogatories for those facts. My motion will ask for issue sanction order that such facts will be taken as established according to my claims about such facts and thereby establishing that birth certificate containing such facts is debtor's birth certificate and thereby establishing that debtor owns real estate and auto dealership under name listed on birth certificate. What say you about such motion for issue sanction order post judgment under CCP 2023.010(g) and 2023.030(b)?

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