Defendant Phuc Dinh Do’s (“Defendant”) motion to compel further responses from Plaintiff Bao Van Lam (“Plaintiff”) to form interrogatories, set one, numbers 2.6, 2.7, 6.2, 6.3, 8.2, 8.3, 8.4, 8.7, and 8.8, form interrogatories, set two, number 12.1, special interrogatories, set two, numbers 3-5, and special interrogatories, set three, numbers 1, 5 and 6 is GRANTED.

When responding to a discovery request, a party has a general duty to conduct a reasonable investigation to obtain responsive information and must furnish information from all sources under his or her control. (Code Civ. Proc. § 2030.220, subd. (c); Regency Health Services v. Superior Court (1998) 64 Cal.App.4th 1496, 1504.) Many of Plaintiff’s responses to the form interrogatories are inconsistent with the information previously provided in response to a request for production of documents and/or the allegations of the complaint. These inconsistencies suggest that Plaintiff did not make a reasonable and good faith effort to obtain the information necessary to provide complete responses. In addition, Plaintiff’s responses do not appear to be as completely straightforward as the information reasonably available to Plaintiff permits. (See Code Civ. Proc., § 2030.220, subd. a.) Accordingly, within 60 days of the date of the filing of the Order, Plaintiff shall serve verified code-compliant further responses, without objection, to form interrogatories, set one, numbers 2.6, 2.7, 6.2, 6.3, 8.2, 8.3, 8.4, 8.7, and 8.8, form interrogatories, set two, number 12.1, special interrogatories, set two, numbers 3-5, and special interrogatories, set three, numbers 1, 5 and 6.

Defendant’s request for monetary sanctions for bringing his motion to compel is GRANTED IN PART against Plaintiff and his former counsel, Duyen Hoang Nguyen, in the amount of $1,350. Defendant prevailed on the motion, there is no substantial justification for Plaintiff’s opposition, and no other circumstances make the imposition of sanctions unjust. Therefore, Plaintiff and Duyen Hoang Nguyen shall pay Defendant’s counsel $1,350, within 20 calendar days of the filing of the Order.

Plaintiff’s request for monetary sanctions for opposing Defendant’s motion to compel is DENIED. Plaintiff’s request is not code-compliant and he is not the prevailing party on the motion.