Legal Question in Civil Litigation in California

I'm glad that you provided more information, which confirms my original response.

1. No, not based on the additional information that you provide. You are mixing up a lot of terms.

In discovery there are three types of responses: a response, which may be vague or incomplete; an objection; and a hybrid response, which contains both an objection and some sort of response.

You use the term incomplete, but then mention objections. As I mentioned in the follow up to your previous post, the responses do not have to be verified to preserve objections. That is the key holding of Blue Ridge v. Superior Court (Kippen) (2nd Dist. 1988) 202 Cal.App.3d 339.

2. The opposition may argue, but the court research staff will most likely see your motion as being untimely as to any responses that contain objections. Again, verification is not required to preserve objections. The argument won't pivot at all. You're out as to any responses that have objections. That includes any response that is a hybrid.

3. The motion to compel further responses will most likely be denied as to any responses containing objections or hybrid objections. Maybe you will get lucky and the judge will be drunk when he reviews all the paperwork you've piled on his desk, but I doubt it. Judges see these kinds of motions all the time and are intimately familiar with the procedure and the rules. The fact that the motions are untimely as to compel further responses to anything objected to deprives the court of power to rule on your motions. The court lacks jurisdiction to compel further responses. Again, it is going to be in the court's research staff checklist, so you are not going to slip out of it.

If the other side is represented by counsel, there is a strong chance that you are going to be sanctioned monetarily, to pay the attorney's fees for them to oppose your untimely motions and show up to court. In other words, you are standing into danger.

It is for this reason that I really suggest you get an attorney, or at least work out an arrangement for legal coaching with a competent attorney if you insist on representing yourself.