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We don't like Motions to Compel. Judges don't like them, and neither do the opposing parties we bring them against. But they are, sometimes, required to be brought in cases where you need information to make sure you know what facts, witnesses and documents are in a case prior to going to going to trial.
Simply repeat what you want the court to do. For example, you could write: ?For the foregoing reasons, Defendant respectfully requests that this Court deny Plaintiff's Motion To Compel.? Sign the motion. Beneath the conclusion, add the words ?Respectfully Submitted? and then insert a signature block underneath.
On motion to compel discovery or for a protective order, the party from whom discovery is sought must show that the information is not reasonably accessible because of undue burden or cost.
Elements to keep in mind while filing the Motion to Compel is to mention the nature of the case, identify the question that needs to be answered or the object or document that is needed and explain how it relates to the case, attach the other party's written refusal to make available the information or object, make it ...
(c) Contents of the Motion the response or objections of the party upon whom the request was served; arguments in support of the motion; and. a certification that the moving party has conferred (or attempted to confer) in good faith with the person or party failing to make a proper response to discovery.