Legal Question in Civil Litigation in California

A) You now have 45 days from service is complete, to meet and confer, and move to compel regarding regarding the Amended Responses. That answer is based on my understanding from your post that the actual responses to the special interrogatories have been amended.

B) The documents is a whole other issue. Inspection demands actually have two different steps, responses, and document production. As to any responses that contain objections or hybrid responses, your motion to compel further responses are still untimely.

C) On this one they actually let the air out of your tires. You can't move to compel production, because they have provided verification. As to your motion to compel further response, it is still untimely.

I disagree with Mr. Roach's answer.

If the other side initially served only unverified responses, then those responses didn't count. An unverified response is no response at all. See Appleton v. Superior Court (1988) 206 Cal.App.3d 632, 636. Your motion sought to compel responses, not further responses. Motions to compel further responses are subject to the 45-day time limit, but motions to compel responses are not. As far as I can tell, your motion was not late.

When a party belatedly responds while a motion to compel responses is pending, the motion does not have to come off calendar. The judge can still decide whether the responses were adequate and can still award sanctions if the original motion asked for them. See Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 410-411. Even though judges have this authority, many will be reluctant to use it. They may want a new motion so that you can explain why you deem the responses inadequate and so the other side will have a chance to address your arguments.

But if you have already taken your motion off calendar, then your only option is to bring new motions to compel further responses.

If your motion asked the court to deem facts admitted and the other side subsequently served proper responses denying those facts, the court cannot deem them admitted due to the delay. That part of your motion was defeated by the untimely responses.