California Rules of Court, rule 3.1345(c) requires that the separate statement in support of a motion to compel further responses provide “all the information necessary to understand each discovery request and all the responses to it that are at issue.” It must also “be full and complete so that no person is required ...
The deadline for finishing discovery (the discovery cutoff) is 30 days before the original date set for a trial unless the parties have agreed or the court has ordered to extend the time. You need all the responses by this date.
In every case, to present an ex parte application to the court, a party must: reserve a hearing date with the applicable department (for applications that require a hearing.) ... file the motion with the court, and. give notice of the hearing date as required by law.
Grounds For Motion – A party may move to compel the answer to a deposition question, or the production of documents at a deposition if the deponent either (1) does not answer a question, or (2) does not bring a document requested in the deposition notice/subpoena. CCP 2025.480(a).
Proc. § 1294(a) (emphasis added). Thus, while the denial of a motion to compel arbitration remains an immediately appealable order, it will no longer trigger an automatic stay in the Superior Court.
Unless otherwise ordered or specifically provided by law, all pretrial motions, accompanied by a memorandum, must be served and filed at least 10 court days, all papers opposing the motion at least 5 court days, and all reply papers at least 2 court days before the time appointed for hearing.