Sample Motion to Compel further responses to Requests for Documents in California
This sample motion to compel further responses to requests for production of documents in California is for use by a party who wants the Court to compel the other party to provide further responses to requests for production of documents. The motion has been revised and updated in March 2018, includes a request for sanctions, a memorandum of points and authorities with citations to case law and statutory authority, a separate statement, sample declaration and a proof of service by mail. The author is a freelance paralegal that has worked in California and Federal litigation since 1995 and has used this sample for many years. Note that the author is NOT an attorney and no guarantee or warranty is provided.