(A party that fails to serve timely responses to requests for admission waives objections to the requests. (CCP 2033.280(a). If the requesting party files a motion to deem the requested matters admitted, the non-answering party is also liable for the fees incurred in bringing the motion. CCP 2033.280(c) also provides that the motion is to be granted unless before the hearing on the motion the non-answering party files proposed responses that are in substantial compliance with CCP 2033.220. This decision holds that while the court may take any objections stated in the proposed response into account in weighing whether the response “substantially complies,” setting forth objections does not automatically make the proposed response noncompliant. Instead, the court should look to whether the responses clearly admit or deny the requests. If they do, they are substantially compliant and the motion to deem the requests admitted should be denied.)