Legal Question in Civil Litigation in California

Yes, in fact discovery documents are not filed with the court at all. You just mail them to each other with proof of service by mail. They are only filed if they are offered as evidence in a motion or at trial, and then as exhibits, not on their own.

Actually, you should have a third party -- i.e. not a party to the lawsuit -- complete the proof of service and mail the documents to the other side. Then, calendar 35 days for the response (30 days + 5 for mailing). If the responses are not satisfactory, you should write a meet-and-confer letter outlining why they are deficient, and mail that to opposing counsel. If satisfactory responses are not forthcoming, then within 45 days of the service of the original responses you must file a motion to compel further responses to preserve your objections to the other party's responses. You might then seek monetary or issue sanctions, or both.

Discovery is not filed with the court unless a discovery motion is filed. However, if you are close to trial you may need to make sure that you have not missed the discovery cut off period. call me at 415-441-1052 if you would like to consult with a lawyer.