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A motion to compel further responses to interrogatories is a prime example. (This is where you've received responses to interrogatories, believe them to be incomplete, and you want the court to order the responding party to provide further responses.)
A separate statement is a separate document filed and served with the discovery motion that provides all the information necessary to understand each discovery request and all the responses to it that are at issue.
Subdivision (a) retains the Nevada rule permitting 40 interrogatories including all discrete subparts in place of the 25-interrogatory limit in the federal rule.
[CCP 2033.280(c)]. Deadline 45 days: Motion to Compel must be filed within 45 days from insufficient response [See Above].
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.
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.