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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 partys 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 notice of any motion to compel must state the following: 1) when and where the hearing will take place; 2) the grounds for the motion, including the specific discovery sought, the statutory authority, and reasons the response is deficient; and 3) the supporting papers (which must also be filed with the motion).
0:00 0:53 And explain why they couldnt respond to it sometimes. We do have to go in front of the judge andMoreAnd explain why they couldnt respond to it sometimes. We do have to go in front of the judge and argue. Maybe they do respond but they do it the night before.
Some of the simple tactics to follow while filing a motion to compel: Act in good Faith. The State and Federal Rules of Civil Procedure require parties to meet and confer before bringing a motion to compel. Thorough Knowledge of the Case. Limit citing voluminous authorities. Avoid Personal Attacks.
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. 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.

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(c) Motions to compel. A person alleging failure to comply with discovery shall file a motion to compel as soon as practicable. A motion to compel shall include the relevant portion of the discovery response at issue.

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