You are entitled to verified responses. Unverified responses are tantamount to no responses at all. As such, you could just file a motion to compel responses (without needing to meet and confer, and without needing to file a separate statement with the motion to compel).
Frank W. Chen has been licensed to practice law in California since 1988. The information presented here is general in nature and is not intended, nor should be construed, as legal advice for a particular case. This Avvo.com posting does not create any attorney-client relationship with the author. For specific advice about your particular situation, please consult with your own attorney.
Discovery responses need to be verified.
If the response was prepared by just the attorney and is solely objections, then a verification is usually not necessary.
If they answered any of the questions, then verification is required, and failure to verify is the same as if they did not answer at all. If they are going to provide a verification within a short period, it might be simpler to just wait, but you could file a motion to compel and to deem their answers admitted.
Unverified responses are meaningless as they are not under oath. Further, all objections to the discovery are waived as a matter of law. You should file a motion to have the requests for admission deemed admitted. You should file a separate motion to compel responses to the special interrogatories.