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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.
Motion to compel further discovery responses Notice of said motion (c) must be served within 45 days of the service of the verified response (five extra days if mailed pursuant to C.C.P. § 1013) or by a specific date agreed upon in writing by both parties; else the right to bring the motion is waived.
Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement, as described below and illustrated by this template.
Must Meet and Confer Prior to Filing a Motion To Compel ? The moving party must include a declaration stating facts that show a reasonable and good faith attempt at an informal resolution of each issue presented by the motion.
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.