You must complete discovery 30 days before your trial. A notice of motion must state in the opening paragraph the nature of the order being sought and the grounds for issuance of the order.A motion to compel is a request to the court to issue an order to compel the other party to answer a question or to produce a document or object. A party has 30 days to respond to written discovery. Typically a discovery motion must at least be filed before the discovery cutoff date. Discovery for settlement purposes is not required. Cut off for discovery is 15 days before trial.