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(Code Civ. Proc., 1005(b).) A motion to compel must contain: 1) a notice of motion; 2) points and authorities; 3) a separate statement; and 4) a declaration that set forth the good faith meet-and-confer attempts to resolve the matter informally.
15 minutes or less and non-evidentiary hearings: Pursuant to Rule 2.530(b) Florida Rules of Judicial Administration, the judge may, upon the courts own motion or upon written request of a party, direct that the telephone be used for a motion hearing, pretrial conference, or status conference.
A motion for continuance shall be in writing unless made at a trial and, except for good cause shown, shall be signed by the party requesting the continuance.
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.
Once a motion to compel is filed, the court will review it and determine whether a hearing is necessary. The court may also issue an order requiring the other party to respond to the motion. If a hearing is scheduled, the parties will have the opportunity to argue their positions.
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If a party in a civil action seeks a ruling on a motion to compel discovery without a hearing, the movant must file the original motion with the Clerk of the Circuit Court and contemporaneously serve opposing party/counsel with the motion to compel.
(c) TIME TO RESPOND. A party may respond to a motion within fourteen days after service of the motion.
(c) TIME TO RESPOND. A party may respond to a motion within fourteen days after service of the motion.

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