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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.
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.
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.
A Motion to Compel Discovery may be filed by any interested party to request the court order an opposing party or a third party to produce a response to a discovery request for documentation or information. NOTE: This event is to compel discovery only.
A motion to compel asks the court to order either the opposing party or a third party to take some action. This sort of motion most commonly deals with discovery disputes, when a party who has propounded discovery to either the opposing party or a third party believes that the discovery responses are insufficient.