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A motion to compel a response to discovery must include: the nature of the questions or request at issue; the response or objections of the party upon whom the request was served; arguments in support of the motion; and.
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.
The motion to compel is used to ask the court to order the non-complying party to produce the documentation or information requested, and/or to sanction the non-complying party for their failure to comply with the discovery requests.
Consider Filing a Motion to Compel if: A party fails to answer an interrogatory. A party's response to a discovery request is incomplete or evasive. A person fails to answer a question during a deposition. A non-party objects to a request for documents under a subpoena.
Identify your reasons for not complying. You need to give the court a reason to deny the other side's motion to compel. There are many different reasons you could give. Take out your Response to the discovery request.