Separate statement: All motions to compel further responses in California state court must include a separate statement in accordance with C.R.C., Rule 3.1345, stating the specific discovery request, the response given, the factual and legal reasons for compelling further responses, etc.What happens if a motion to compel is denied in California?
Then there are the California codes and rules of court governing: A misstep at any point may result in denial of the motion and a waiver of the right to compel further responses. Of course if you are on the receiving end of the motion to compel, you’ll need to know your deadline for opposing the motion, the format for doing so, etc.When does a motion require a separate statement?
The motions that require a separate statement include a motion: (2) To compel further responses to interrogatories; (3) To compel further responses to a demand for inspection of documents or tangible things; (5) To compel or to quash the production of documents or tangible things at a deposition;What is a motion to compel further responses to interrogatories?
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.)