22CV46038
PLAINTIFFS’ MOTION TO COMPEL FURTHER RESPONSES
This is a quiet title action involving an easement for ingress and egress between
adjoining parcels APN 012-004-005 and APN 012-004-019, which plaintiffs describe as
an easement of necessity given the remoteness of the cabin thereon and the loss of an
access bridge previously available to plaintiffs. Before the Court is plaintiffs’
commingled motion for further discovery responses to both production requests and
special interrogatories. Although the practice of filing commingled motions for further
responses is generally frowned upon, a review of the papers reveals a relatively simple
solution.
As for the merits, a review of the papers on file reveals that defendants’ written
responses are not Code-compliant. A party responding to special interrogatories has an
obligation to provide responses which are “as complete and straightforward” as
possible, which obligates the party to make a “reasonable and good faith effort to obtain
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