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The federal rules do not contain any time limit in which a motion to compel discovery must be filed. But you should check your court's local rules and even the judge's standing order. For instance, in the Northern District of California you must move to compel within seven days of the close of discovery.
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.
SUPPLEMENTAL REQUEST FOR PRODUCTION If, for any reason, any response is no longer correct or complete, identify the response and state and/or provide copies of whatever information and/or documentation is necessary in a verified response to make it correct and complete as of this date.
Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above].
If you falsely deny a document exists, It is also possible that you might object to one or more of the requests. To raise an objection you would write ?Responding party objects on the grounds? followed by the basis of your objection(s).
A Motion to Compel is a formal request to the Court to require a party or a non-party in a lawsuit to comply with a discovery request such as a request for production, request for admission, interrogatory, or subpoena.
Grounds For Motion ? A party may move to compel the production of documents or things if the response (1) agrees to comply, but compliance is incomplete, (2) the responding party's indication of inability to comply is incomplete, inadequate, or evasive, or (3) an objection to a request is made that is too general or ...
The motion to compel is used to ask the court to order the non-complying party to produce the documentation or information requested, and/or to sanction the non-complying party for their failure to comply with the discovery requests.