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The motion to compel further responses has to be brought within 45 days of service of the response. (C.C.P. 2030.300) Sounds simple enough, but its not. You have to understand when something is deemed served.
If any Party becomes legally compelled to disclose any Confidential Information of another Party (whether by judicial or administrative order, applicable law, rule or regulation, or otherwise), that Party shall use all reasonable efforts to provide the other Party with prior notice thereof so that the other Party may
Rule 81 requires use of a special summons which commands that the defendant appear and defend at a specific time and place set by order of the court and informs him or her that no answer is necessary.
Service. A subpoena may be served by a sheriff, or by his deputy, or by any other person who is not a party and is not less than 18 years of age, and his return endorsed thereon shall be prima facie proof of service, or the person served may acknowledge service in writing on the subpoena.
When that happens, a party can file a motion to compel, asking the Court to order the opposing party to produce the contested documents or information. If a motion to compel is granted and the Court orders the information produced, failing to comply with that order can lead to serious consequences.
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Hence, under the original wording of Rule 81(c), where a case is filed less than 20 days before the term and is removed within a few days but before answer, it is possible for the defendant to delay interposing his answer or presenting his defenses by motion for six months or more.
Under T.R. 53.2, if a judge takes a cause tried to the court under advisement and fails to determine any issue of law or fact within ninety (90) days of the submission of all pending matters, the case may be withdrawn from the judge. Ind.
The defendant shall have thirty (30) days from the date of first publication in which to appear and defend.
1 to cause (someone) by force (to be or do something) 2 to obtain by force; exact. to compel obedience. 3 to overpower or subdue.
Courts enforce their orders by imposing sanctions on a party who fails to comply. Sanctions can be monetary, such as requiring one party to pay the other parties attorneys fees and/or imposing a monetary fine, or they can hamper a partys ability to put on their case.

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