Plaintiff seeks further responses from Truinject to special interrogatory numbers 2, 3, 4, 7, 8, 10, 20, and 25.  The motion is granted in part and denied in part, as set forth below.

For interrogatories, each answer in the response must be “as complete and straightforward as the information reasonably available to the responding party permits. If an interrogatory cannot be answered completely, it shall be answered to the extent possible.” (Code Civ. Proc., § 2030.220, subds. (a) & (b).) Where the question is specific and explicit, an answer that supplies only a portion of the information sought is improper.  It is also improper to provide “deftly worded conclusionary answers designed to evade a series of explicit questions.” (Deyo v. Kilbourne (1978) 84 Cal.App.3d 771, 783.)

A motion to compel also lies where the party to whom the interrogatories were directed gave responses deemed improper by the propounding party; e.g., objections, or evasive or incomplete answers. (Code Civ. Proc., § 2030.300; see Best Products, Inc. v. Superior Court (2004) 119 Cal.App.4th 1181, 1189-1190 [motion to compel proper to challenge “boilerplate” responses]. If a timely motion to compel further responses has been filed, the burden is on the responding party to justify any objection or failure to fully answer the interrogatories. (Coy v. Superior Court (1962) 58 Cal.2d 210, 220-221; Fairmont Ins. Co. v. Superior Court (2000) 22 Cal.4th 245, 255.)

Truinject argues that Plaintiff did not meet and confer in good faith after the Court issued the parties’ stipulated protective order on February 24, 2021, that a responding party does not have a duty to supplement after a protective order is issued, and that Truinject’s responses are proper and its objections are meritorious. Plaintiff has sufficiently met and conferred before bringing this motion.  (Flores Decl., at ¶¶ 6, 8, and 9, Exhs. D, E, G, H, and I; Beus Decl., at ¶¶ 5-6, Exhs. D and E.)

Truinject did not meet its burden to justify its objections and refusal to fully respond to special interrogatory numbers 2, 3, 4, 7, 10, and 25.  Accordingly, Plaintiff’s motion is granted as to these interrogatories.  Plaintiff’s special interrogatory number 4 is limited to the time period from 2016 to April 19, 2019.

Truinject shall serve supplemental, verified, Code-compliant responses, limited to non-privileged information, to these interrogatories within 20 days.

Truinject has met its burden to justify its objections to special interrogatory number 8.  Truinject has shown that no further response is required as to special interrogatory number 20.  (Code Civ. Proc., § 2030.230; Truinject’s Separate Statement, at p. 86:19-20.)  Accordingly, the motion is denied as to special interrogatory numbers 8 and 20.

The Court declines to award any sanctions.

Plaintiff shall give notice of the ruling.