Distinguishing Andrews v. Foster Wheeler (2006) 138 Cal.App.4th 96 and following Gaggero v. Yura (2003) 108 Cal.App.4th 884 instead, this decision holds that no logical inference that the plaintiff possesses no facts to support his claim can be drawn from the plaintiff’s improper use of the procedure under CCP 2030.230 (pointing to documents from which an answer can be drawn) in response to contention interrogatories.  Therefore, the improper answers cannot be treated as “factually devoid” or satisfy the moving party’s initial burden of proof on summary judgment.  The defendant’s only recourse on receiving the improper answers is to move to compel proper answers.