California Sample Letter conveying Joint Motion for Leave to Propound Additional Discovery
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How to fill out Sample Letter Conveying Joint Motion For Leave To Propound Additional Discovery?
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FAQ
The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (4) To compel answers at a deposition; (5) To compel ...
Section 2025.480 - Motion to compel answer or production (a) If a deponent fails to answer any question or to produce any document, electronically stored information, or tangible thing under the deponent's control that is specified in the deposition notice or a deposition subpoena, the party seeking discovery may move ...
§ 1005, subd. (b), and Cal. Rules of Court, Rule 3.1300.) Oppositions to motions to compel must be filed no later than 9 days before the hearing.
Meet and confer: A prerequisite to bringing a motion to compel further responses is a reasonable and good faith attempt to informally resolve the issues presented by the motion. The motion must include a ?a good faith declaration,? stating that the attempt was indeed made.
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.
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.
You must file a separate motion for each of the discovery responses you wish to compel. For example, if you served both form interrogatories and requests for production, and got no answer to either, you will need to file two separate motions.
