Motion to compel discovery california. Deposition Notice – Defendant may serve any time.

) What constitutes a good faith meet-and-confer effort depends on a variety of factors. §2031. Aug 23, 2021 · In California, a party may file a Motion to Compel Deposition to enforce a deponent's attendance, testimony, and document production when the deponent fails to appear for examination or produce the requested documents without serving a valid objection. ICC Collision Centers, Inc. In a formal discovery, you formally ask for information and documents. The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party Motion to Compel Discovery Superior Court of California San Diego Timing 45 Days After Insufficient Responses to Written Discovery. Too many defense lawyers think discovery is due after a motion compelling it gets granted. CCP § 1005 (b) (amended eff 1/1/23). 300(b), 2031. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the Jan 1, 2016 · Except as provided in 3. Plaintiff Jan 28, 2020 · What does motion to compel mean and how does the process work? If you find yourself entangled in the legal process, read further for an overview of what a motion to compel entails. S. 2008) Appeal, § 2, pp. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; Sep 21, 2016 · On June 16, 2016, a California Court of Appeal, in an unpublished decision, issued yet another ruling applying the doctrine of waiver to arbitration agreements in the employment litigation context. > > Read More. Rule 37 provides that a party may seek to compel discovery when, as here, a responding party fails to answer an interrogatory or refuses to provide requested documents or information. 040 requires that parties meet and confer in a “reasonable and good faith attempt at an informal resolution of each issue The normal discovery timeline and standard of review for the aforementioned motion are provided below. ) In a few situations, a discovery ruling may meet the requirements of a statute providing a right to direct appeal. ” A party may move to compel further responses to interrogatories on the grounds that the answer is evasive or incomplete, an exercise of the option to produce documents under the Code of Civil Procedure § 2030. Co. Reply in Support of Motion to Compel Discovery Superior Court of California Sacramento. These motions, brought under California Code of Civil Procedure (CCP) sections 2025. (Id. 240). B. 240(b) does specifically not state the Below is a sample motion to compel discovery. Now what do you do? First, take a deep breath. Find step-by-step instructions, templates, deadlines, and tips for Sacramento County. – Defendants, CASE NO. 020, the discovery cut off and the cut off for motions seeking discovery responses is based on the initial trial date. Reply papers must be filed and served at least 5 court days before the hearing date. 2024 California Rules of Court. compel discovery in California for use in an out-of-state proceeding, the out-of-state party must: (1) submit the original subpoena from the foreign jurisdiction where the case is pending (or a true and correct copy), see Cal. The purpose of this motion is to request an order from a Jul 12, 2024 · What is a Motion to Compel? If a party fails to answer a question, attend a deposition hearing, or fails to bring a document or tangible thing requested in a deposition notice or subpoena, then the party seeking the discovery may request the court for an order to compel an answer or to compel the production of a document or object. 1345 states that a "separate statement" is required when filing a motion to compel responses or further responses to a discovery request. The practice guides--Weil and Brown, Civil Procedure Before Trial (TRG 2019), CEB California Civil Discovery Practice (2019) 4th Ed. 300 (requests for production) authorize motions to compel responses where no responses have been provided within the 30-day timeframe during which Motion to Compel Discovery Superior Court of California Sacramento Timing 45 Days After Insufficient Responses to Written Discovery. 290(c) Delaying the filing of the motion waives a party's right to compel further responses. Jul 7, 2024 · Motion to Compel Discovery Superior Court of California San Bernardino Timing 45 Days After Insufficient Responses to Written Discovery. Fed. 172. 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; Nov 16, 2020 · Before moving to compel discovery responses, California law requires that the parties “meet and confer. 13 discovery. (Pacific Tel. Sandvick worked as a civil litigator in California for over 7 years. (Subd (a) amended A motion to compel is a document filed in a court proceeding asking the judge to force the other party to do something. 310(c) and 2032. KRAMER, State Bar //094049 MICHAELH. at p. Coreas,Deputy Clerk 1 JEFFREY S. 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; Jan 22, 2022 · This article was co-authored by Clinton M. Superior Court (1983) 147 Cal. Most often, motions to compel are used in “discovery” disputes when one party doesn’t want to answer questions or sit for a deposition. 300(a); (2) pay a fee of $20 per subpoena Nov 14, 2019 · The purpose of the “meet and confer” requirements set forth in C. Before a party files a motion to compel a response to discovery, the party must make a good faith effort to confer with the person or party allegedly failing to properly respond to a request for discovery in an effort to secure information or material without action by the ALJ. 208. ) Motion to Compel Discovery . , Universal-Polygram International Publishing, Inc. 020] Practical Last Day to Serve Discovery (and be able to make a motion on it) – 90-100 days before trial. b. This motion is particularly relevant under the California Penal Code 1054, which governs the discovery process in criminal cases. 310, 2032. If the motion is granted — or if the disclosure or requested discovery is provided after the motion was filed — the court must, after giving an opportunity to be heard, require the party or deponent whose conduct necessitated the motion, the party or attorney advising that conduct, or both to pay the movant’s reasonable expenses incurred (c) The court shall impose a monetary sanction under Chapter 7 (commencing with Section 2023. Motion To Compel PDF. If a dispute arises during a discovery event and counsel believe that prompt resolution of the dispute would result in savings of expense or time, counsel may contact the chambers of the assigned District Court or Magistrate Judge to address the problem by telephone The court may toll the deadline for filing a discovery motion if an Informal Discovery Conference is requested pursuant to CCP §2016. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the Motions to compel versus motions to compel further responses. , a cross-complaint or discovery, you must follow several steps, in the proper order. 4th 871, 893. Procedure (5th ed. Some arbitrators allow informal discovery conferences and require a formal motion only if the matter is unresolved during the informal discovery conference. 020] Last Day to Hear Discovery Motions – 15 days before trial. According to this section, “[i]f an informal resolution is not reached by the parties, as described in § 2016. Code § 2029. No discovery motions may be brought on an ex parte basis, unless a showing is made of irreparable injury or prejudice not attributable to the lack of diligence of the moving party. Discovery motions in summary proceeding involving possession of real property (a) Notice In an unlawful detainer action or other action brought under chapter 4 of title 3 of part 3 of the Code of Civil Procedure (commencing with section 1159), notice of a discovery motion must be given in compliance with Code of Civil Procedure sections 1010. What is a motion to compel? A motion to compel asks the court to enforce a request for information relevant to a case. . Informal discovery means sharing information voluntarily. Here is a general sequence of events leading The court may toll the deadline for filing a discovery motion if an Informal Discovery Conference is requested pursuant to CCP §2016. 8) Meet and Confer is not technically required if no responses have been received, but in practice Court is more likely to grant sanctions if you made an attempt to meet and confer prior to filing. U. Discovery closes before trial: 30 days before trial – or 15 days before arbitration. This is the most common discovery motion we file. 010) against any party, person, or attorney who unsuccessfully makes or opposes a motion to extend or to reopen discovery, unless it finds that the one subject to the sanction acted with substantial justification or that other circumstances make the imposition of the sanction unjust. Timing. He received his JD from the University of Wisconsin-Madison in 1998 and his PhD in American History from the University of Oregon in 2013. Proc. & Tel. 480 (pdf)? Does it mean the conduct that led the moving party to make the motion has to be substantially justified? Or does it mean the decision to make or oppose the motion to compel has to be substantially justified? Motion to Compel Discovery Superior Court of California Riverside Timing 45 Days After Insufficient Responses to Written Discovery. If you chose option three, then you must prepare a privilege log. When Can You File a Motion to Compel Discovery? A Motion to Compel can be filed only after you have made a formal discovery request under Federal Rules of Civil Procedure 33, 34, 36, or 45 Feb 18, 2010 · The discovery statutes in California require that trial discovery be completed 30 days before trial otherwise your attorney has two options #1 Ask for a continuance of the trial date due to late disclosure #2 Ask for sanctions at trial for failure to disclose. Dec 1, 2015 · Motion to Compel Discovery United States District Court Northern District of California. As to 15 those requests, defendants' answers are sufficient for the reasons explained below. Under Code of Civil Procedure § 2024. There can be no doubt that motions to compel discovery (“MTC”) and motions to compel further responses to discovery (“MTCFR”) are the most common of all discovery motions. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the JOINT STIPULATION to MOTION to Compel DISCOVERY RESPONSES FROM VEOH NETWORKS 71 REDACTED filed by Plaintiffs Songs of Universal, Inc. 1345. (Mills v. 173. §§ 2025. This saves time and money. Timing Deadline for Service of Motion to Compel - Ten (10) Days Before Hearing. 040. (Code Civ. Download Template as PDF. 6 or 1013 and 1170. The court may impose sanctions for non-cooperation in the discovery motion procedure. But, to prepare for trial, you will use the formal discovery process. Motions to compel in general. 6 has not been complied with may serve and file with the administrative law judge a motion to compel discovery, naming as respondent the party refusing or failing to comply with Section 11507. , Rondor Music International, Inc. Carter, Executive Officer/Clerk of Court, by L. If you manually calculate the last day to take a particular action, e. 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; Dec 6, 2018 · Motions to compel are often necessary to set the tone in your case and acquire the documents and information you need to win your case. 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; Oct 26, 2021 · motion to compel - motion to compel initial responses [motion compel 2 of … Preview Electronically FILED by Superior Court of California, County of Los Angeles on 09/30/2019 08:47 AM Sherri R. Although C. Calculating the Deadline In this era of pandemic and stay-home orders, we are seeing an uptick in billing opportunities by the defense, many involving issues dealing with discovery and non-compliance with the discovery statutes. 310(b), 2032. See blog “If Meet and Confer Fails, Ask for Help. ) Furthermore, California’s liberal approach to permissible discovery generally has led the courts to resolve any doubt in favor of permitting discovery. Bank (2008) 166 Cal. The Federal Rule provides that a motion to compel discovery or for sanctions may be brought either in the court where the action is pending or in the place where the discovery or deposition is taken. Because AB 2230 amends provisions regarding motions to compel only as to three types of discovery motions, the advisory committee considered the alternative of amending the rule only as to those three types. App. \par \par }{\rtlch\fcs1 \af1\afs24 \ltrch\fcs0 \b\f1\fs24\insrsid6636930\charrsid6636930 D. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the May 14, 2021 · Before filing a motion to compel discovery responses, the parties must engage in a "reasonable and good faith attempt at an informal resolution of each issue presented by the motion. 230 is unwarranted or the required specification of those documents is inadequate, and/or an objection to an interrogatory is without merit or too general. Thus, if a deposition were being taken in another state or Federal district, the parties do not have to adjourn the deposition and return to the Pursuant to California Rule of Court 3-1345 a motion to compel must include the following parts: (c) Contents of separate statement 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. App. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the plain reading of California Rule of Court, Rule 3. There are numerous articles on how to file motions to compel and general discovery motion practice tips and strategies. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the Jan 1, 2023 · (i) Failing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning discovery, if the section governing a particular discovery motion requires the filing of a declaration stating facts showing that an attempt at informal resolution has been made. 1345(b), any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. The Court urges counsel to stipulate to extend the 45-day timeframe in which to file a Motion to Compel. Motion to Compel Discovery Superior Court of California Orange Timing 45 Days After Insufficient Responses to Written Discovery. . Rule 3. Motion to Compel - Motion to Compel Motion to Compel - Interrogatories Preview Electronically FILED by Superior Court of California, County of Los Angeles on 01/18/2019 05:07 PM Sherri R. , supra, 2 Cal. conference (see supra, ¶ V) before any discovery motion will be heard in a Lemon Law case. Motion to Compel. Chong 2 3325 Wilshire Boulevard Sep 9, 2010 · You have been served with the Motion to Compel Further Responses with a Separate Statement of Items in Dispute the size of your fist and your response is due in two weeks. 040, the court may conduct an informal discovery conference upon request by a party or on the court's own motion for the purpose of discussing discovery matters in dispute between the parties. California Code of Civil Procedure sections 2030. " (Code Civ. , Universal Music - Z Tunes LLC, Universal Music - MBG Music Publishing Ltd. P. Discovery can be informal or formal. Apr 7, 2011 · There are three motions that you can bring--(1) Motion to Compel, (2) Motion to Compel Further Responses, and (3) Motion to have matters Deemed Admitted. (A) To Compel Disclosure. The motions that require a separate statement include a motion: (1) To compel further responses to requests for admission; (2) To compel further Jul 1, 2022 · Motion to Compel Discovery Superior Court of California San Mateo Timing 45 Days After Insufficient Responses to Written Discovery. (CCP §1170. LR 37-4. fn. ” But what do you actually have to do to meet that requirement? California Code of Civil Procedure section 2016. , a defendant waited eight months after responding to a complaint before bringing its motion to compel arbitration. All of them have their place in your discovery plan but two of them --Motion to Compel Further Responses and Motions to Have Matters Deemed Admitted must be in your arsenal. (9 Witkin, Cal. 24-C-04-008432 MT. A motion to compel discovery is a motion brought by a party asking the court to compel another party, or third party, to provide certain disclosures or discovery. Proc Motion to Compel Discovery Superior Court of California San Francisco Timing 45 Days After Insufficient Responses to Written Discovery. Sanctions for failure to provide discovery (a) Sanctions despite no opposition The court may award sanctions under the Discovery Act in favor of a party who files a motion to compel discovery, even though no opposition to the motion was filed, or opposition to the motion was withdrawn, or the requested discovery was provided to the moving party Sep 5, 2012 · Just wondering, but what does the phrase "acted with substantial justification" mean in the sanctions statute for motion to compel depo testimony, CCP 2025. In Ogannesian v. 290 was for the lawyers to revisit their position, and in good faith, discuss a resolution in order to avoid unnecessary discovery motions. Sandvick, JD, PhD. (c) Unless notice of this motion is given within 45 days of the service of the verified response, or any supplemental verified response, or any specific later date to which the requesting party and the responding party have agreed in writing, the requesting party waives any right to compel further response to the requests for admission. Caldwell] San Francisco Superior Court Case Number 303 753 Los Angeles Superior Court Case Number BC 210894 © 2024 Judicial Council of California Jun 24, 2016 · Rule 3. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the Section 11507. If I am composing an OPPOSITION to such a motion, do I have to include a separate statement also? Jun 14, 2022 · Therefore, the party seeking discovery is entitled to substantial leeway. Motion to Compel Discovery Superior Court of California Contra Costa Timing 45 Days After Insufficient Responses to Written Discovery. 300(c), 2031. 1 This [71 Cal. Oct 20, 2022 · On October 17, 2022, the California Court of Appeal, Fourth Appellate District, Division 3, issued a decision in Golf & Tennis Pro Shop, Inc. 250, 2033. MANDY GLENN- Plaintiff v STEVEN KENNEDY, et al. ” The present motion to compel compliance does not involve the content of a discovery request or response. IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND. 2d 278] is an appropriate case, under The two most common discovery motions are motions to compel responses and motions to compel further responses. ”Continue Reading When Do I Have to Bring a Motion to Compel Written Discovery? Motion to Compel: Can be filed at any time upon 5 days notice. Except as provided in 3. , to move to compel further responses to discovery, or you manually calculate the last day to respond to something, e. This is a standard motion to compel. Format of discovery motions. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the insufficient Feb 20, 2012 · You need to do separate motions to compel. 37(a)(3)(B)(iii)-(iv). Normal Discovery Timeline. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the Except as provided in 3. In most jurisdictions, a motion to compel must be made on notice to other parties and all affected persons. a. Motion To Compel Word Document. : 201409 Law Offices of Edward J. While typically filed with respect to discovery responses in civil litigation, they may also be filed for other reasons such as to compel compliance with a prior court order. C. 3d 681 at 685 (Pre Motion to Compel Discovery Superior Court of California Los Angeles Timing 45 Days After Insufficient Responses to Written Discovery. (See CCP 2030. 1348. Any motion involving the content of a discovery request or the responses to such a request must be accompanied by a separate statement. Clinton M. Format of discovery motions (a) Separate statement required . (3) Specific Motions. 6. During those eight months, the court Deadlines must be calculated at every phase of the California state court lawsuit. Deposition Notice – Defendant may serve any time. 7 - Motion to compel discovery (a) Any party claiming the party's request for discovery pursuant to Section 11507. 1347. Though they appear to be the same motions you would use for Petitioners seek a writ of mandate to compel respondent superior court to set aside its orders of July 25, and November 25, 1968, respectively sustaining objections to petitioners' requests for admissions and denying petitioners' motion for further responses to written interrogatories. 250 and 2033. Before filing a motion to compel: Ask the arbitrator if a formal motion to compel is required. 1345(a), which provides that a separate statement is required for “[a]ny motion involving the content of a discovery request or the responses to such a request…. Jan 20, 2024 · In California criminal law, a motion to compel discovery is a critical tool used by defense attorneys to ensure they have access to all the evidence in a case. The other person must respond to your request and swear how they responded is true. 300, 2031. This is the time you decide when to "hold them and when to fold them" because how you respond may end up setting the tone between you and opposing counsel for the entire case. 8. There also are numerous seminars on law and motion practice, which I encourage you to attend. California Discovery Citations (TRG 2019) ¶1:6 citing Parker v. v. 5 Court Days Before the Hearing. 3(a)(4)(B). § 180. Sanctions for failure to provide discovery (a) Sanctions despite no opposition . 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; Jan 31, 2012 · In responding to Requests for Production of documents you have three response choices (1) agree to produce (C. 3d at p. ) The separate statement requirement was designed to streamline adjudication of discovery motions, and a failure to file a separate statement is a sufficient basis for denying plaintiff’s motion to compel. 280. Civ. However, it decided that to amend the rule as to all motions for which separate statements are required was more logical and efficient. 220); (2) state that after a diligent search and a reasonable inquiry you have no documents (C. Feb 11, 2014 · Inadequacy of Review of Discovery Rulings on Appeal from Final Judgment. Central Dist. However, one of the most common errors is to treat these motions as if they were the same – they are not. in regard to document production requests. (a) If a deponent fails to answer a question propounded, or a party upon whom a discovery request has been made fails to respond adequately, objects to a request, or fails to produce documents or other inspection as requested, the discovering party may move the ALJ for an order compelling discovery in Basic Motion To Compel. Phila. [5] Section 2034, subdivision (a), provides that if a motion to compel is denied and the court finds that the motion was made without substantial justification, the court may require the payment to the opposing party of reasonable expenses incurred in connection with the motion, including reasonable attorney's fees. Except in cases of emergency or waiver by consent of all parties, at least ten (10) days prior written notice is required. Superior Court holding that interrogatory responses containing a combination of unverified factual responses and objections only trigger the 45-day clock to bring a motion to compel when the responding party serves its subsequent verifications. The case of Vidal Sassoon, Inc. This Blog/Web Site is made available by the lawyer or law firm publisher for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice. ” Continue Reading When Do I Have to Bring a Motion to Compel Written Discovery? Apr 23, 2018 · Few motions strike more fear (or at least boredom) into the hearts of attorneys than the dreaded Motion to Compel Further Responses to Discovery. In California, the right to appeal is wholly statutory. 010 et seq. 290 are enormously time-consuming, technical and costly. Grounds: When a party who has propounded discovery believes the responses are inadequate, the propounding party may move for a motion to compel a further response. 540 Motion to compel discovery. 230) or (3) object (C. CCP §§ 2030. Horan,Deputy Clerk 1 State BarNo. [CCP 2024. , Universal Music Corp. It is the Court’s general practice “to toll the deadline for filing a discovery motion” in order to allow for an Informal Aug 20, 2010 · The purpose of discovery sanctions is not to provide a weapon for punishment, forfeiture, and the avoidance of the trial on the merits, but to prevent abuse of the discovery process and correct the problem presented. , § 2016. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the A motion for an order to a nonparty must be made in the court where the discovery is or will be taken. 480, 2030. If a party fails to make a disclosure required by Rule 26(a), any other party may move to compel disclosure and for appropriate sanctions. 290 (interrogatories) and 2031. Dispute During Discovery Event. 080 or 2033. Jul 23, 2018 · discovery requests and the production of responsive documents in accordance with FRCP 33 and 34. Defendants have answered the vast majority of that discovery to plaintiffs' 14 satisfaction, except for the relatively few requests at issue in the instant motions to compel. and Matthew Bender Practice Guide: California Civil Discovery-- are good starting points when preparing your motion. You cannot file a Motion to Compel simply because the other party refuses to respond to any of your informal requests for information. Motion to Compel Discovery Superior Court of California Alameda Timing 45 Days After Insufficient Responses to Written Discovery. Carter, Executive Officer/Clerk of Court, by M. 61-62. The Courf 16 should therefore deny plaintiffs' motions to compel. No Ex Parte Discovery Motions. A party on whom written discovery has been served, must Jan 1, 2016 · Except as provided in 3. Pennsylvania Court of Common Pleas Philadelphia County. Motion to Compel To avoid the Judge denying the motion to compel on procedural grounds, if any form of response, including just objections, or unverified responses, are served; to avoid inadvertently allowing the statutory deadline to file a motion to compel further discovery responses to elapse, one should meet and confer and serve notice of motion to compel SUPPORT OF MOTION TO COMPEL FURTHER JURISDICTIONAL DISCOVERY [Filed concurrently herein with Sporting Arms and Ammunition Manufacturers' Institute Inc. (a) Separate statement required. Aug 5, 2010 · Motions to compel further responses to interrogatories, requests for productions of documents and requests for admissions require that the motion be filed within 45 days. ) Except as provided in 3. (B) To Compel a Discovery Response. ' s Opposition to Plaintiffs' Motion to Compel; Declaration of Susan L. }{\rtlch\fcs1 \af1\afs24 \ltrch\fcs0 \f1\fs24\insrsid6636930\charrsid6636930 The court may award sanctions under the Discovery Act in favor of a party who files a motion Learn how to file a motion to compel discovery responses in California civil cases. 450(b)(2), 2025. , Universal Music - MGB NA LLC, UMG Recordings, Inc. P. Feb 23, 2018 · California Rule of Court 3. g. Motion to Compel Discovery Superior Court of California Santa Clara Timing 45 Days After Insufficient Responses to Written Discovery. If the responding party has provided insufficient responses to interrogatories, requests for production of documents, or requests for admission, the requesting party must give notice of motion to compel further responses within 45 days of service of the insufficient Nov 26, 2023 · A “motion to compel” is a written motion in which you ask the court to force the other side in a lawsuit to do something. in regard to interrogatories and 2031. Different CCP setions govern motions to compel further responses to interrogatories and motions to compel fuirther responses to request for production of docuements. Download Template as DOCX. Court May Impose Sanctions Despite Lack of Opposition to Motion to Compel Discovery. R. yz oc st ri on xk pn ku ep yr